HomeMy WebLinkAbout95-05507
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JINNIrlR J. ZULLI,
PlainUff
I IN THE COURT or COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 'l f- .,~ 50 1 {t~)..:.J._, J-L-~"-
I
I CIVIL ACTION - LAW
I CUSTODY
v.
DONALD N. ZULLI,
Detendant
DRDB D. CODI'
AND NOW, upon con.ideration of the attached Coaplaint,
it i. hereby directed t a ~h. partie. and their r.spective
coun.el appear before , (~14,. I "h~c., the
Conq~iator, on the ~ ayof f , 3t'''S,IC''th~
U~lL at ~. o'~ .m., , {,,.,,,.Iir,
Coii{t.w4...~..U.ale, iiinn.Ylvania, for a Pre-Hearing Cu.tody .
Conterenc.. At such Conferenca, an effort will be made to
resolva the i..ues in dispute; or if this cannot be accomplished,
to detine and narrow the i..ue. to be heard by the Court, and to
enter into a Teaporary Order. All children age. five or older
shall elso be preaent at the conference. Failure to appear at
the Conference aay provide 9round. for the entry of a teaporary
or peraanent order.
For the court,
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YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE
SET rORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Date of Order I
I {J-f8<;)"
BYI
COURT ADMINISTRATOR
Cumberland County Court Houue
4th Floor
1 Courthouse Square
carlisle, PA 17013-3387
(717) 240-6200
....
JINNlrlR J. ZULLI, , IN THI COURT or COMMON PLIAS
Plaintiff , CUMBBRLAND COUNTY, PENNSYLVANIA
,
v. , NO.
,
DONALD N. ZULLI, , CIVIL ACTION - LAW
Dsf.ndant , CUSTODY
CDII.LJlln .01 CU.I'ODY
1. Th. Plaintiff i. J.nnif.r J. zulli, r..iding at
5110 Arn.y Road, H.rri.burg, Dauphin County, p.nn.ylvania 17111.
2. Th. D.f.ndant i. Donald N. zulli, r.siding at 268
luaqu.hanna Av.., Inola, Cuaberland county, p.nn.ylvania 17025.
3. Plaintiff ...ks cu.tody of the following child,
11II
Nikola. A. zulli
'...aMr ..IID..a.
au
5110 Arn.y Rd.
Harrisburg, PA 17111
Th. child was not born out of w.dlock.
2
The child i. pre..ntly in the cu.tody of the
Plaintitt, J.nnit.r J. Zulli, who r..id.. at 5110 Arn.y Rd.,
Harrisburg, PA 17111.
During the pa.t five (5) year., the child has r..id.d
with the tollowing p.r.ons and at the following addre....'
11II
R..ID.IICI
DO
Donald N. and
J.nnit.r J. Zulli
Jennit.r J. zulli'
Christoph.r o. Allen
268 su.quehanna Ave. 9/26/93 to 10/10/95
Enola, PA 17025
5110 Arney Rd. 10/11/95 to pr...nt
Harri.burg, PA 17110
Th. mother of the child i. Jenniter J. Zulli, currently
re.iding at 5110 Arney Rd., Harri.burg, PA 17110. She i.
aarried to Donald N. Zulli.
The father ot the child is Donald N. zulli, currently
re.idin9 at 261 Su.quehanna Ave., Enola, PA 17025. He i.
aarried to Jenniter J. Zulli.
4. The relationship ot the Plaintitt to the child i.
that ot Mother. The Plaintitf currently resides with the
following persons I
11II R.LJl~IO...I.
Mikola. A. Zulli Son
Chriatopher o. Allen rriend
5. The relationship of the Detendant to the Qhild i.
that ot rather. The Defendant currently re.ides with the
tolloving per.on.,
11II R.LJlI'IO.I.I.
Alexander C. We.ton Friend
6. Plaintiff ha. not participated a. a party or
witnes., or in another capacity in other litigation concernin9
the custody ot the child in this or another court.
Plaintiff has no information of a custody proceeding
concerning the child pending in another court of this
Coaaonwealth.
Plaintiff do.s not know of a person not a party to the
proceedin9 who ha. phy.ical custody of the child or claim. to
have custody or vi.itation rights with respect to the child.
7. The beat intere.t and permanent weltare of ths
child will be ssrved by vranting the relief requested because it
1. in the child's best intere.t.
I. Bach parent who.e parentel rights to the child have
not been terminated and the person who has physical cu.tody of
the child h.s besn named a party to this action. There are no
other parties who are known to have or claim a right to cuetody
or vi.itation ot the child.
WHERBFORE, Plaintiff reque.t. the Court to grant
custody ot the minor child, Nikola. A. zulli.
Re.pectfully sub.ittad,
rRIEDMAN, P.C.
. r e .an, sq.
. Second strset
oU.e suite
P.O. Box 984
Harrisburg PA 17108
(717) 236-8000
Dats.
~9(
VUI'ICA.'I'ION
I, Jenniter J. Zulli, hersby acknowledve that I am the
'laintitt in the torevoinv action, that I have read the forevoinv
C~laint tor cuatodYI and the tact. stated therein are true and
oorrsct to the bast ot my knowledgs, information and baliet.
1 underetand that any fal.e statementa herein are made
.ubject to penalties ot 11 Pa. C.S. Ssction 41104, relating to
unevorn talsitication to authoritie..
DateclI lolu/i<
JENNIFER J. ZULLI, ) IN THE COURT OF COMMON PLEAS
Plelntlff I OF CUMBERLAND COUNTY,
I PENNSYLVANIA
VI, I
I CIVIL ACTION. LAW
DONALD N. ZULLI, I NO. 96.6607 CIVIL TERM
Defendent )
) CUSTODY
ORDER
AND NOW, thll If:> dev Of~' 1996, upon receipt of
the Concllletor'e R.port, It eppeerlng that the pertlel have egreed to the terml end
provlelonl of thle Order which wel dlctet.d In their prelence end epproved bV them
and their counlll, It II her.bv ord.red .nd directed el followl:
1. LIgII cUltodV of the minor child, Nlcholae A. Zulli. d.o.b. 23
Sept.mb.r 1993, II Ihered bV the pertlae.
2. Prlmery phVllcel cUltodv of the minor child Ihell be with
Moth.r .ubject to perlodl of pertlel cUltodv and vllltatlon with Fether
ae followl:
A, Altern.tlng waekend. from Frldav at 8:30 e.m, until
Sund.v et 7:00 p.m.
B, On all other FrldaVI from 8:30 a.m. until 4:00 p.m.
C. Everv Tualdev from 8:30 a.m. until 4:00 p.m,
The drop off for the Frldav and Tueldav visitation shall be at
the meternalgrandmother'l hOUSI, PatlV Sola.
3, Thl psrtle. will altlrnate the following holldaYI:
Thanklglvlng, Now Vear'. Day, ellter, Memorial Day, Fourth of July.
end Labor Day. Theae .he holld.YI will be divided Into two equallltl.
the flrlt let Including Thanklglvlng, ealter, and Fourth of JulV, end the
lacond lit Including New Vear'l Day, Memorial Dav, and Labor Day,
Mother will h.ve the flr.t lit beginning with Thenklglvlng, 1996, end
F.thlr will h.va the lecond lit beginning with New Yearl Dev, 1996.
The partlel will thin alternate thlle IItl on a vear-to-ve.r belli.
4, Tha Chrl.tmal holldav will be divided Into two IIgmantl.
Thl flrlt IIgment will be from 23 D.cember at noon until Chrlltm.1
Dav at noon. The lecond .Igment will be from Chrl.tmll Dav at noon
until Chrlltmal Dev at 8:00 p.m. Mother will have the firlt IIgment
In 1996. Fethlr will hava the flrlt legmont everv third v.er thereafter.
6. Mother will have tha minor child on Mother'. Dav end Father
will have the minor child on Father'l Dav. Thll Ichedule will take
precedence over anv other Ichedule,
8, Father will be provided with three non-conllcutlve weekl
over the lummer monthl. Father II to provide Mother with notice of
thOle three weekl bV 1 Mav of each year.
7. The pertle. will Ihare time on the minor chlld'l blrthdav. It
II the Intention of thll Order that the parties work out an arrangement
10 thlt elGh of thlm ars given 10m. tlm. .t or n..r the minor chlld'l
blrthdlY to c.l.brlt. hll blrthdlY, //
/
J.
Richard S. Frlldmln, Elqulre
Attorney for Plllntlff
Mlrk Thom.. SllIIklr, Elqulr.
AttomlY for Olf.ndlnt
mlb
VS.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY.
PENNSYLVANIA
CIVIL ACTION - LAW
NO. 96-6607 CIVIL TERM
JENNIFER J. ZULLI.
Plaintiff
DONALD N. ZULLI.
Defendant
CUSTODY
JUDGE PREVIOUSLY ASSIGNED: None (No Judicial Conflicts)
CUSTODY CONCIUATlON CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1 916.3-B(bl. the undersigned Custody Conciliator submits the
following report:
1, The pertinent Information concerning the child who Is the subject of this
IItlg.tlon Is as follows:
NAME
BIRTHDA TE
CURRENTLY IN
CUSTODY OF
Nlcholal A. Zulli
23 September 1993
Plaintiff IMother
2. A Concllletlon Conference was held on 9 November 1996. and the
following Individuals were present: the Plelntlff and her attorney. Richard S.
Friedman. Esquire; the Defendent appeared with his attorney. Mark Thomes SlIlIker.
Esquire.
3. Items resolved by agreament: See attached Order.
4. Issues yet to be resolved: None.
1
6. The Plelntlff'l pOliti on on cUltody II 81 followl: See ettlched Order,
8. The Oefendlnt'l pOlltlcn on cUltody II II followl: See Ittlched Ordlr.
7, Neld for Ilperlte counlel to reprel8nt child: Neither plrty reque.ted Ind
thl Conclllltor doel not bllleve seperete counsel Is needed.
8, Nled for Independent psychologlcl' eVlluatlon or counseling: Neither
Plrty reque.ted and the Conclllltor does not belllvelt Is neceslary,
Oltl: 13 Novemblr 1996
'.
;,-
Ichlel L. Blngs
CUltody Conclllato
2
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LA W
IN CUSTODY
JENNIFER CHRISTOPHER,
(fonnerly Jennifer Zulli),
PlalntllT
v,
DONALD N. ZULLI,
Defendant
NO. 95-5507
CIVIL TERM
aBI1.fICATION Ot' St;RVIC~
I, Brenda Coppede, Certified Legallntem, Family Law Clinic, hereby certify that I have
served a Inle and correct copy of the Petition to ModifY Custody on Donald N. Zulli, residing at
125 Columbia Road, Enola, PA 17025, by depositing a copy of the same in the United States
mall, certified. restricted delivery, retum receipt requested, Service was complete upon receipt by
Donald N. Zulli on August 8, 2005, as evidenced by the attached green card with the article
number 7005 03900003 2632 4754.
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Family Law Clinic
45 North Pitt Street
Carlisle, P A 17013
(717) 243.2968
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JENNIFER CIIRISTOI'IIER (fORMER!. Y
JENNIFER ZUW)
1'!.AINTIFf
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
95-5507 CIVil. ACTION LAW
DONALD N. ZULU
DEFENDANT
IN CUSTODY
ORln:R OF COllin
AND NOW, Wednesday, July 17,1005 . upon considcration of thc ultllchcd COl11pllllnl.
il is hereby dircctcd thaI panics ami their rcspcctlvc counselllPPcllr bclilrc Itubert X. Gilroy. Elq. .thc conciliutor.
al 4111 Floor, Cumberland Counly CourlhOUle, Cullsle on Friday. AUIUII16,1005 ull0130 AM
for a Prc-lIearlnl! Cuslody Conlercncc. At such confercncc. IIn clli1l1 will bc I11l1dc III rcsolve thc Issucs in dispulc; or
Iflhls cannol be accomplished, 10 delinc and nllrrow Ihc issucs 10 bc hcard b)' Ihc coun,und 10 cntcr Inlo II tCl11pOrul')'
order. All chlldrcn a~c I1I'C or older l11ay ulso bc prcscl1llltlhc conferencc. Failurc to uppcur mlhc conlercncc mu\'
provide I!rounds filr entry of a tCl11porary or pcnllllllcnlordcr,
The court hereby dlrecll Ihe parI lei 10 furnllh Ilny and ull ellltlnK "rolectlon from Ahule orden,
Specllll Relief ordera.llnd CUllody orden 10 Ihe conelllulor 48 houn prior 10 Icheduled hellrlnll.
FOR TIlE COURT.
lIy: III
Hubert X. Gllror. E,q.
Custody Concililltor
..Y
Thc counofConllllon l'lcas ofCumbcrlund County is rCljulrcd by law 10 comply with Ihe Americans
wllh Dlsnblllles Aclor 1990. For inlilmmtion about acccsslble lilcilllics IInd reasonable accol11modalions
uvallablc to disablcd individuals hlll'lnl! buslncss bclilre thc courl. pleusc contllclour onice. Allurranl!cments
mUst be madc IItlcast 72 hours prior 10 any hcurinl! or husincss bclhre Ihc coun. YOUlllust ultend the schcduled
conlercncc or heurinl!.
YOU SHOULD TAKE TillS I'APER TO YOUR ATTOItNEY AT ONCE. IF YOU DO NOT
IIA VE AN ATTORNEY OR CANNOT AFFORD ONE. (iO TO OR TELEPllONE TIlE (JI'FICE SET
FORTIIIIELOW TO FIND OUT WIIElm YOU CAN GET LEGAL IIELP.
CUl11bcrlllnd County Bur Assoclution
32 Smilh IIclllilfd Slrcct
Cllrllslc. I'cnnsylvuniu 17013
Telcphonc (717) 249-31(,6
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~ECEIVED JUl 22 21m &
JENNIFER CHRISTOPHER,
(fonnerly Jennifer Zulli).
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LA W
IN CUSTODY
v.
DONALD N. ZULLI,
Defendant
NO. 95-5507
CIVIL TERM
9RDER OF COURT
AND NOW, this day of ,2005. upon consideration of the attached
complaint, it is hereby directed that the parties and their respective counsel appear before.
, the conclliator. at , , on the day of
.2005, at , for a Pre-Hearing Custody Conference. At such conference, an
effort wlll be made to resolve the issues in dispute; or of this cannot be accomplished, to define
and narrow the issues to be heard by the court and to enter 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 pennanent order.
The Prothonotary In Dauphin County (No. 2031 CV, 1996) has been notified that this
matter has been transferred to Cumberland County.
FOR THE COURT:
By:
Custody Conclliator
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER 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 Ll berty A venue
Carlisle, PA 17013
(717) 249-3166
Amerlesns With Disabilities Ad of 1990
The Court of Common Pleas of Cumberland County Is required by law to comply with the
Americans with Disabilities Act of 1990. For infonnatlon about accessible facllitles and
reasonable accommodations available to disabled Individuals having business before the court,
please contact our office. All arrangements must be made alleast 72 hours prior 10 any hearing
or business before the court, You must allend Ihe scheduled conference or hearing.
"
JENNIFER CIIR1STOI'IlER,
(fonnerl)' Jennifer Zulli).
Plalnllff
v,
IN TIlE COURT Oil COMMON I'LI!AS ()II
CUMIU!RLANI> COUNTY ,I'I!NNSYI.V ANIA
CIVIl. ACTION. LA W
IN CUSTOI>Y
DONALD ZULLI,
Defendanl
NO, 9S.SS07
CIVIL TI!RM
NOTICE 7'ODE"'END
YOU IIA VE miEN Slll!lllN COllin, If )'IIU wllh 10 defelld allalnlllhe claims sel forth
In the followlnll palles. )'ou lIIulllake acllllll wlthllllwenl)' (20) da)'1 aller Ihls cllmplalnt and
nollce are served, b)' enlerhlll a wrltlen appearallce persollall)' IIr b)' allll",e)' alld tlIll1l1l11 wrlllnll
wilh Ihe court )'our defenses ur ubJcellunslu Ihe clahul sel forth allah'll )'UU, You are wamed
thallI' )'uu fall 10 du IU Ihe ease ilia)' pruceed wlthoUI )'UU alld a Judlllllclllllla)' be enlered allalnsl
)'ou b)' Ihe court wlthoul further 11111 Ice lilr all)' IIIl1l1e)' clahned In Ihe cUlllplalnlor fur an)' IIlher
claim or rellefrcquesled b)' Ihe plallllllT. YUUIIIIl)' IIIICIIIIIIIIl)' ur rrullllrt)' ur ulher rlllhls
Importanllo )'ou,
YOU SllOUI.\) TAKI! TillS l'AI'H1\ TO YOIll\ I.A WYlilt AT ONCIi, IF YOll 00
NOT IIA VE A LAWYER OR CANNOT AFFoltU ONI!, UO TO Olt TIiLl!I'llONI! Tim
OFFICE SET FORTllIlBl.OW TO I/INI> OUT WIlI!lUi yOU CAN nl!T I.I!UAI, llELI',
THIS OFIlICE CAN I'ROVIIlI! YOU WITIIINFORMATION AIIO\)'!' IIIRINO A LAWYER,
IF YOU CANNOT AFFORI> '1'0 IIIR\! A I.AWYI!R, TlIIN OWIl'1! MAY III! AIJI.I! TO
PROVIDE YOU WITJlINIlORMATION AllnllT AlII!NCII!S TIIAT MA Y OFFER LEOAL
SERVICES TO EI.IOmLl! l'I!R!iONN AT A IUiI>U('I!I> 111m 01\ NO FI!I!,
CUlllllllrlalld ('11I11I1)' liar Auuclallllll
32 !ioulh Iledlilrd !ilreel
('arlllle.I'IlIIIII)'lvanla 17013
(717) 241).3IfJtt
AM..:RICANH WI'I'II UlNA"'''''"",:N AC'I' n..' 1990
'nle Cuurt UI'ClIlIIllllIlIl'lelll 111' CUlllherhllld CIIUIII)' 18 rcllulred b)' law 10 com pi)' wllh
the Alllerlealls with 1>1811hlllllel ACluf 11)1)11, Fur Inlimnllllun abuulllcccsslble faelllllcs and
reasollablc aecunllnmllllllllll Ilvllllabllllu dllllhled IlIdlvldllall hllvlllll buslllC81 before Ihe court,
pleasc Clllllacluur IItllce, Alllurllllllelllellll 1111111 be Illllde allcall 72 hours prior 10 any hcarinl!
or bUllnel1 be tine Ihe cllutl. YUUIIIIlllllllemllhe 8cheduled cunferellcc or hearinl!.
"
.
.
JENNIFER CHRISTOPHER,
(fonnerly Jennifer Zulli),
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LA W
IN CUSTODY
v.
DONALD N. ZULLI,
Defendant
NO. 95-5507
CIVIL TERM
W1T10N TO MODIFY CUSTODY ORDER
I. The Petition of Jennifer Christopher, by her attorneys, the Family Law Clinic,
respectfully represents that on February 27,2002, an Order of Court was entered for custody of
Nlkolas J. Zulli, born September 23,1993. A true and COITCCt copy of the Order Is attached as
"Exhibit A."
2. Under the existing Order, Donald N. Zulli (Father) has primary physical custody
of the child and Jennifer Christopher (Mother) has partial physical custody. The parties share
legal custody ofthe child.
3. This Order should be modified because:
a. Father voluntarily relinquished primary physical custody of the child
in August 2004 to Mother. Mother has maintained primary physical
custody of the child during the school year, and the parties have been
alternating weeks of custody during the school summer vacation
months.
b. Father cannot provide a stable, consistent living situation for the
child. He alternates between living with his parents and his
girlfriend and does not have a home of his own,
c. Father has not pruvlded financially for the child since August 2004
and Is unable to do 50 because he Is cUlTCntly paying child support
for two other children.
d. Mother has been Ihe child's primary carelaker since August 2004.
'.
.
.
VERIFICATION
I verifY that the statements made in this Custody Complaint are true and correct to the
best of my personal knowledge and belief. I understand that false statements herein are made
subject to the penalties of 18 l'a.C.S. 4904, relating to unsworn falsification to authorities.
Date: Yi ~ 0 ::,
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Plalnllff
IN THE COURT OF COMMON PLEAS
DAUPHIN COUNTY, PENNSYLVANIA
DONALD N. ZULLI,
v.
NO. 2031 CV, 1996 ~ -."
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JENNIFER J. ZULLI, now known as
JENNIFER J. CHRISTOPHER,
DefendanVPetllloner
ORDER OF COURT
1t! .1.. j j
AND NOW, to wit, this v"l day of rc7Jl.tPl.il CU..'1 ,2002, the parents and
v
their respective counsel, having appeared for a Custody Conference on February 7, 2002, before
the Conference Officer, Sandra L. Mellton, Esquire, and having reached agreement with regard to
the best Interests end welfare of their minor child, Nlkolas J, Zulli, bom September 23, 1993, Ills
hereby ORDERED AND DECREED as follows:
The Order entered by this Court on Ssptember 18, 1998 Is modified as follows:
1. The parents shall share legal custody of Nlkolas and each parent shall
consult with ths other concerning all major decisions affecllng Nlkolas, Including but not limited to,
health, education and religion.
2. Primary physical custody of Nlkolas shall be with Father, Donald N. Zulli.
3, Mother, Jennifer J. Zulli, shall have partial physical custody of Nlkolas In
accordance with Ihe following schedule:
a, During Ihe school year, on altematlng weekends from Friday after
school through Sunday at 7:30 p.m.
b. During the school year, every Tuesday from after school through
7:30 p,m,
HBG:2066.2.016569.016936
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c. Paragraph b., c. and d. under the original order are hereby deleted.
4. The parents will alternate the following major holidays: Easter, Memorial
Day, Fourth of July, Labor Day, Trick or Treat Night and thanksgiving. The custodial period shalt
run from 10:00 a.m, through 6:00 p.m. with tha excepllon of Trick or Treat Night which shall be
from efter school until 8:30 p.m. The schedule shall begin with Mother having Trick or Treet Night,
1998,
5, The Christmas holiday shall be divided Into two Segments, Segment A
shall be December 24 at 3:00 p,m. through December 25 at 3:00 p,m. Segment B shall be
December 25 at 3:00 p,m, through December 26 at 3:00 p.m. Commencing with December 1998,
Mother shall have custody during Segment A and Father during Segment B. Thereafter, the
parents shall altemate custody of Nlkolas In accordance with the Segments.
6. New Year's Day shall also be shared by the parties on an altemallng bases
wllh the party who has Christmas Day also having New Year's Day. The New Year's Day
holiday shall run from 10:00 a.m. through 6:00 p.m. Under this schedule, Mother shall have New
Year' a Day In 2003.
7. Father shall have custody of Nlkolas on Father's Day from 10:00 a.m.
through 6:00 p,m. and Mother shall have custody of Nlkolas on Mother's Day from 10:00 a.m.
through 6:00 p.m.
8, During Nlkolas' summer vacallon from school, the parties shall share
custody on an alternallng weekly basis. The transfer of custody shall take place on Fridays at a
mutually agreed to lime. Tho schedule shall begin wllh Father having the beginning Friday,
June 7 and running through Friday, June 14. The slart of the summer schedule Is designed to
accommodate the fact that Father has already scheduled a one week summer vacallon to run
HBO,2065.2.0' 5569.0 16936
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RECEIVED
NOV I 6 l005
BY:.
JENNIFER CHRISTOPHER
. (FORMERLV JENNIFER ZUI.LI),
Plalntl"
VI.
I IN TlU; COURT OF COMMON PLEAS OF
I CUMBERLANDCOUNTV, PENNSYLVANIA
I
I NO. 9S.S!I07 CI VI L ACTION. LA W
I
IKlNALI) N. ZULLI,
llefrndant
I IN CUSTOUV
ORDER
It
AND NOW, thll I (' day of November, ZOOS, the Conciliator belna advised
the parties have rached an aareement, the Conciliator relinquishes Jllildlcllon.
Respectfully lubmltted,
FilED (li'neE
OF n I~ r""), """1TAny
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2005 NDV '7 I'rl 21 13
C':' I ""'Y
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I IN TilE COURT OF COMMON PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO.9S-5!107 CIVIL ACTION. LAW
I
I IN CUSTODY
I
JENNIFER CHRlSTOpER,
pl.tall"
DONALD N. ZULLI,
Defendlnt
~
AND NOW, tbll 7J() d.y of M.reb,l006, upon con.ldenllon of the .ttacbed
Cu.tody Conciliation Report, 1111 ordered .nd directed .. follow'l
I. T"e Mother, Jennifer Cbrlltopber, .nd tbe F.tber, Don.1d N. ZulU, .h.U enjoy ....red
Itpl eu.tody ofNlkolu A. ZuUI, bom Seplember 13,1993.
1. p..y.leal eu.tody .b.U be b.ndled a. follow'l
A. Durin. tile .d1ool ye.r, Ibe mlaor cblld .h.11 mlde wltb tile Mother durla. tile
week .ad .blU mlde with the F.tber every weekend from FrId.y after "hoo!
uatllSunday evenlla a17100 p.m.
B. Durin. the .ummer month., the partin .hall alt.mate eu.tody on a week
oalwttk off bull, Ihe dale of lIehaa.e to be arran.ed be,ween the partin.
C. The partla m.y .hare or .Uemate holiday. a. tbey a.rtt.
D. The partin mlY modify the above .chedule a. Ibey a.rtt. Abient an
a.rttment, Ihe above .cbedult .h.1I conlrol.
3. In the event either party dlllrn to modify Ibll Order, Ihll party mlY petition Ihe
Court to have Ihe ca.e a..1n .cheduled for a cu.lody conclllallon conference.
... Punuanl 10 Ibe alrttmenl of the p.rtlll, Ihe p.rtlll will execute .11 .pproprl.le
documenlallon a. required 10 .llow F.lher 10 claim the minor child I' . dependent on
hll Fedenllncome relum In even numbered ye.n .nd Mother 10 clllm Ihe minor
child .. her dependent In odd numbered ye.n.
~
Judie
CCI ~ll Smith, .:.qulre \
vM', T.n Yutzy "
"
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.
JENNIFER CHRlSTOPER,
Plaia 11ft'
I IN THE COURT OF COMMON PLEAS OF
I CUMBERLANDCOUNTY,PENNSYLVANIA
I
, NO. 95.5!107 CIVIL ACTION. LAW
,
I IN CUSTODY
I
v
DONALD N. ZULLI,
Defendant
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 19IU-I(b), the undenlped Cu.lody ConcUlator .ubmlta tlae follow'"
report:
I. n. pertiaent lafo.....tto. pertal.Ia,lo the cblkl who II the .ubJtcl of thllllttptioa II
u followl'
Nlkolu A. ZulU, bom September 13, 1993
1. A ConclUallon Co.fere.ce WII held on March 13, 1006 with the followl..lndlvldua"
In a..tIId..cel
ne Mother, Jennifer Chrtalopber, wllh her .tudent a..omey Tan Yutzy of the
DleklnlOn Mool of Law Family Law Cllnle
ne Fatlaer, Do.ald N. ZulU, wllh hll cou.lIl, Mall Smllh, Elqulre
3. n. partitlaareed to the entry of an Order In the form a. a"ached whleh wID replace
tile Daupllla County Order e.lered al No. 1031.1996.
~
Dater March ;;J ~ , 1006
A
lIubert X. G lroy, Elqulre
Cu.lody nclllator
,-
mNNll'l:R CIIIUSTOI'III:R
1'l.^1 NTI 1'1'
IN lIlE CIIUIff' OF ('IIMMON PI.E^S OF
CUMIIEltl.ANIl ('OUNn', I'ENNSYI. VANIA
v,
'~.~~07 l'IV11. MTIIIN LA W
I>ON^LI> N. ZULLI
IlI'l'l:NIMNT
IN ('USTOI>Y
ORIlt:R OF COllin
AND NOW, __J:.hund.r..'tb.!UI!'Y.I.~.Z,~~__.___._, upon consldcnulon oflhc ullllchcd Cnmplllhu,
Ills hereby directed tlllll plll11cs IInd Ihelr respcclive counsclllPPcllr hcli'rl' lIubtrl X. (iIIrll)'. .:Iq, , Ihe coneilllltor,
lit .elh .'1001'. Cumberl.nd Coull!): C'!.urth~"!"~lrll!!!.. on,.._..J~I1Urld.~!~!Ir~I1.Z}.J ~!!!l~____,.. 1I1 .!z30 AM
fIll' n Pre-Ilenr!n!! Custody Confercncc, AI such conlercncc, IIn ellill1l1'ill he mlldc to rcsolve Ihe Issucs In dlspule; or
iflhls cllnnot be IIccomplished. 10 del1nc nnd nllITOII' Ihe issucs 10 hc hCllrd by Ihc cOUI1, nnd to cnter huo u lemporal)'
order. All children nile live or oldcr 0111\' IIlso hc presenl nt Ihc cnnlercncc, Fllllure 10llPIlcllr IIllhc conlerence mnv
provide grounds iiII' cntry of IIlcmpnrnry nr pcnlll1ncnt ordn,
The cuurl herch)' dlreclllhe IIMrllcllu furllllh Mil)' Mnd Mil edlllnlt I'rlllccllnn frllm Ahllle urdcrs,
Sped" Rellcf orders. and CUllud,' ordenlu lhc cllndllMlur 411 huu... 111'1111' lu Ichedulcd heMrlllK.
FOlt TilE COURT.
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('uslod)' Concililllor j
The COUI1 ol'Conllllonl'lclls ol'l'lImhcrlllnd ('ounly Is rcquired hy 11I1I' In l'ompl)' lI'ilh Ihc Americllns
with Dlsllblllles Act of 11)90, Fur inlill'lnllllonllhoulllccessihle Iilcilillcs IInd rCllsonllhle IIccomlllodllllons
IIvnllllble 10 dlsllhled Indivldllllls hllvlng hllslncss hclhrc Ihc courl, plcllsc conlllct 1'\11' olllcc, Allllrrungcmellls
llIust bc mllde 1I11cllst n hours priur 101lny hCllring or huslncss hclin'c Ilw cOllrt. YOII muslllucmllhc schedulcd
coulercnce or hCllrlng,
\'OU SIIOULI> TAKE TillS PAI'Er( TO YOUII ATT< lIlNEY AT IINCE. IF YIIU DII NOT
IlA VI: AN ATI'OIINEY Olt CANNOT AITIIIU> liNE, (jll TII olllFl.El'llONE lIlE oITI('E SET
FOlnll IIEWW TO FINIlIIUT WIIEfU' YIIU CAN <lET I.I'<IAI.III'I.I'.
Cllmherlllnd COllnl) 1I11r Assoclalion
J~ SOllth IIcdlill'll Slrccl
ClIrllslc.l'cnnsyhllnill 17[11.1
Telcphonc (717) ~4"I,.1111h
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RECEIVEn rFn I a 7(l(lfi,~~
: IN TI IE COURT OF COMMON PLEAS OF
: CUMIJERLAND COUNTy.pi:NNSYLVANIA
: CIVIL ACTION - LA W
: IN CUSTODY
. ,.
.
,
Ji:NNIFER CHRISTOPHER,
Plaintiff
v.
DONAI.D N. ZULLI.
l>efendanl.
: NO. 9S.SS07
CIVIL TERM
~
AND NOW,Ihls day of ,2006, upon considerallon of
Ihe allached complalnl, ills hereby dlrecled Ihallhe parties and Ihelr respective counsel
appear before, , Ihe concilialor. at , on Ihe day of
. 2006. al_ m., for a Pre-Hearing Cuslody Conference. AI
such conference. an effort will be made 10 resolve Ihe issues In dispule: or Iflhls cannol
be accomplished. 10 define and narrow Ihe Issues 10 be hcard by Ihe court, and 10 enler
Inlo a lemporary order. All children age five or older may also be presenl oflhe
conference. failure 10 appear allhe conference may provide grounds for enlry of a
lemporary or pennanenl order.
TIae court hereby direct. the plrtlll to furnl.b any and all fllllllnl Protection
From Abult orden, Special Relief Orden, and Cu.tody orden to the conelllalor ..8
laoun prior 10 Ibe .dlfduled bearlnl.
fOR THE COURT:
Oy:
Cuslody Concilialor
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AfFORD ONE. GO TO OR
TELEPHONE THE OfFICE SET fORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
CUMBERLAND COUNTY OAR ASSOCIATION
32 S. Bedford SI.
Carlisle. I'A 17013
(717) 249.3166
AMERICANS WITII mSAOILlTlES ACT OF 1990
The Court of Common Pleas ofCumbcrland Counly Is required by law 10 comply wilh
Ihe Americans wilh Dlsabililles Acl of 1990. For inlhnnallon aboUI accessible facililles
and reasonable accommodallons avail 10 disabled individuals havlnl! business before Ihe
court. please conlact our olllce. All arrangemcnts must be made atleasl 72 hours prior 10
\,
.
.
any hearing or business before the court. You must attend the scheduled conference or
hearing.
. ,
JENNIFER CHRISTOPHER,
Plaintiff
In the Court of Common Pleas
Cumberland County, Pennsylvania
v.
DONALD ZULLI,
Defendant
Civil Action - Custody
No. 95-5507
Civil Tcnn
Petition to Sch~dule Conciliation
I. The Petitioner Is Jennifer Christopher. She Is an adult Individual currently
residing at 257 South Pitt Street, Carlisle, Cumberland County, Pennsylvania.
2. The Respondent Is Donald Zulli. He is an adult Individual currently residing at
125 Columbia Road, Enola, Cumberland County, Pennsylvania.
3. A Petition to Modify Custody was llIed on July 21, 2005.
4. The Custody Conclllation was scheduled for November 10, 2005.
S. The conciliation was cancelled because the parties thought they came to an
agreement.
S. Negotiations between the parties broke down and the parties were unable to
I1nallze an agreement.
6. Pursuant to Rule 206-2(c), Defendant's attorney of record, Max Smith. Esquire.
was contacted to seek concurrence. Mr. Smith no longer represents the Defendant In this
matter.
WHEREFORE, the Petitioner respectfully requests the court schedule a custody
conciliation In the above-captioned matter.
Date: d/~rit
A NAL - X
LUCY JOHNSTON-WALSH
THOMAS M. PLACE
ROBERT E. RAINS
Supervl.lng Attomeys
FAMILY LAW CLINIC
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: IN mE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION. LAW
: IN DIVORCE
JENNIFER CHRISTOPHER,
(fonnerly Jennifer Zulli),
Plaintiff
DONALD ZULLI,
Defendant
: NO. 95.5507 CIVIL TERM
TO THE PROTHONOTARY:
Kindly allow Jennifer Christopher. Plaintiff, to proceed In fonna pauperl..
The Family Law Clinic, attorneys for the party proceeding In forma pauperis,
certifies that we believe the party is unable to pay the costs and that we are providing free
legal service to the party.
Date 1/2//0'-
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243.2968
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JENNIFER CHRISTOPHER,
(formerly Jennifer Zulli),
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION - LAW
IN CUSTODY
DONALD ZULLI,
Defendant
NO. 95-5507
CIVIL TERM
NOTICE TO DEFEND
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 twenty (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 1he 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 LA WYlER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO
PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania ]7013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities 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.
JENNIFER CHRISTOPHER,
(formerly Jennifer Zulli),
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
CIVIL ACTION - LAW
IN CUSTODY
DONALD N. ZULLI,
Defendant
NO. 95-5507
CIVIL TERM
PETITION TO MODIFY CUSTODY ORDER
I. The Petition of Jennifer Christopher, by her attorneys, the Family Law Clinic,
respectfully represents that on February 27,2002, an Order of Court was entered for custody of
Nikolas 1. Zulli, born September 23,1993. A true and correct copy of the Order is attached as
"Exhibit A."
2. Under the existing Order, Donald N. Zulli (Father) has primary physical custody
of the child and Jennifer Christopher (Mother) has partial physical custody. The parties share
legal custody of the child.
3. This Order should be modified because:
a. Father voluntarily relinquished primacry physical custody ofthe child
in August 2004 to Mother. Mother has maintained primary physical
custody of the child during the school year, and the parties have been
alternating weeks of custody during the school summer vacation
months.
b. Father cannot provide a stable, consistent living situation for the
child. He alternates between living with his parents and his
girlfriend and does not have a home of his own.
c. Father has not provided financially for the child since August 2004
and is unable to do so because he is currently paying child support
for two other children.
d. Mother has been the child's primary l:aretaker since August 2004.
e. Mother is best able to provide the child with a home with the moral,
emotional and physical surroundings Jrequired to adequately meet the
child's needs.
f. The child has been attending school in the Carlisle School District
for the past year. Mother resides in the Carlisle School District;
Father does not. The child is well-adjusted to his current school and
is involved in many extra-curricular activities. The child is emolled
in the Carlisle School District for the 2005-2006 school year.
g. Mother continues to exercise parental duties on behalf ofthe child
and enjoys the love and affection ofthe child.
h. Mother will encourage the child to de:velop and maintain a strong
relationship with the child's father.
WHEREFORE, Plaintiff requests that the Court grant shaJred legal custody to Plaintiff
and Defendant, primary physical custody of the child to Plaintiff, and partial physical custody to
Defendant at times mutually agreed upon by both parties.
Date: 7/21 !~t)
{
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Certified Legal Intern
~ / ~~L
~ NALD-FOX
LUCY JOHJI/STON-WALSH
THOMAS M. PLACE
ROBERT E. RAINS
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, Pa 17013
(717)243-2968
VERIFICATION
I verify that the statements made in this Custody Complaint are true and correct to the
best of my personal knowledge and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities.
Date: ,I) \~ 0 0
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Plaintiff
IN THE COURT OF COMMON PLEAS
DAUPHIN COUNTY, PENNSYLVANIA
DONALD N. ZULLI,
v.
NO. 2031 CV, 1996 = -c
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JENNIFER J. ZULLI, now known as
JENNIFER J. CHRISTOPHER,
Defendant/Petitioner
ORDER OF COURT
AND NOW, to wit, this
\277if day of ~!Ul.LLaUj
1/
, 2002, the parents and
their respective counsel, having appeared for a Custody Conference on February 7,2002, before
the Conference Officer, Sandra L. Meilton, Esquire, and having reached agreement with regard to
the best interests and welfare of their minor child, Nikolas J. Zulli, born September 23, 1993, it is
hereby ORDERED AND DECREED as follows:
The Order entered by this Court on September 18, 1998 is modified as follows:
1. The parents shall share legal custody of Nikolas and each parent shall
consult with the other concerning all major decisions affecting Nikolas, including but not limited to,
health, education and religion.
2. Primary physical custody of Nikolas shall be with Father, Donald N. Zulli.
3. Mother, Jennifer J. Zulli, shall have partial physical custody of Nikolas in
accordance with the following schedule:
a. During the school year, on alternating weekends from Friday after
school through Sunday at 7:30 p.m.
b. During the school year, every Tuesday from after school through
7:30 p.m.
HBG:2065-2-015569-018936
f xhihif A
- 1 -
c. Paragraph b., c. and d. under the original order are hereby deleted.
4. The parents will alternate the following major holidays: Easter, Memorial
Day, Fourth of July, Labor Day, Trick or Treat Night and Thanksgiving. The custodial period shall
run from 10:00 a.m. through 6:00 p.m. with the exception of Trick or Treat Night which shall be
from after school until 8:30 p.m. The schedule shall begin with Mother having Trick or Treat Night,
1998.
5. The Christmas holiday shall be divided into two Segments. Segment A
shall be December 24 at 3:00 p.m. through December 25 at 3:00 p.m. Segment B shall be
December 25 at 3:00 p.m. through December 26 at 3:00 p.m. Commencing with December 1998,
Mother shall have custody during Segment A and Father dUling Segment B. Thereafter, the
parents shall alternate custody of Nikolas in accordance with the, Segments.
6. New Year's Day shall also be shared by the parties on an alternating bases
with the party who has Christmas Day also having New Year's Day. The New Year's Day
holiday shall run from 10:00 a.m. through 6:00 p.m. Under this schedule, Mother shall have New
Year's Day in 2003.
7. Father shall have custody of Nikolas on Father's Day from 10:00 a.m.
through 6:00 p.m. and Mother shall have custody of Nikolas on Mother's Day from 10:00 a.m.
through 6:00 p.m.
8. During Nikolas' summer vacation from school, the parties shall share
custody on an alternating weekly basis. The transfer of custody shall take place on Fridays at a
mutually agreed to time. The schedule shall begin with Father having the beginning Friday,
June 7 and running through Friday, June 14. The start of the summer schedule is designed to
accommodate the fact that Father has already scheduled a one week summer vacation to run
HBG:2065-2-015569.018936
-2-
from July 22 through July 27. To the extent that beginning the schedule with Father having the
week of June 7 through 14 does not give Father the week of June 22 through June 27; the parties
shall adjust the schedule to assure that Father has the vacation time which he has already
reseNed.
9. The parties shall share September 23 which is NikoJas' birthday. It is the
intention of this Order that the parties work out an arrangement so that each of them has some
time with Nikolas on the 23rd of September.
10. In the event that either parent finds it n,ecessary to use a third party care
provider for Nikolas, that parent shall offer the other parent the right of first refusal with regard to
providing daycare.
11. It understood and stipulated by the parents that, upon their mutual
agreement, an expanded or altered schedule may be agreed between the parents for and in the
best interests of Nikolas.
12. This matter shall be heard again by th,e Conference Officer on May 10,
2002 at 10:30 a.m. at 111 North Front Street, Harrisburg, Pennsylvania 17101.
BY THE COURT:
Chc~ /~
2065.2
J.
J/tAY 1 3 2005
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tru!e,aOO ",C,(,)('"I,"';'.'"C<]lfiY of ii,S: original
filed,
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H8G:2065-2-015569-018936
- 3 -
JENNIFER CHRISTOPHER (FORMERLY
JENNIFER ZULLI)
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
95-5507 CIVIL ACTION LAW
DONALD N. ZULLI
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW,
Wednesday, July 27, 2005
, upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq.
at 4th Floor, Cnmberlaod Couuty Courthouse, Carlisle on Friday, Aneust 26,2005
, the conciliator,
at 10:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effOli 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 mav also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
Tbe court bereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to tbe conciliator 48 bours prior to scheduled heartn!!.
FOR THE COURT,
By: Isl
Hubert X. Gilroy, Esq.
Custody Conciliator
y
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 ] 70 13
Telephone (717) 249-3166
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RECEIVED JUL 222005
JENNIFER CHRISTOPHER,
(formerly Jennifer Zulli),
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
DONALD ZULLI,
Defendant
: NO. 95-5507 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
TO THE PROTHONOTARY:
Kindly allow Jennifer Christopher, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis,
certifies that we believe the party is unable to pay the costs and that we are providing free
legal service to the party.
Date 1 ~/ /(),-
RENDA COPPE
Certified Legal Intern
~~;~
ANNE. CDONALD-FOX
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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JENNIFER CHRISTOPHER,
(formerly Jennifer Zulli),
Plaintiff
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DONALD N. ZULLI,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CNIL ACTION - LAW
IN CUSTODY
NO. 95-5507
CIVIL TERM
CERTIFICATION OF SERVICE
I, Brenda Coppede, Certified Legal Intern, Family Law Clinic, hereby certifY that I have
served a true and correct copy ofthe Petition to ModifY Custody on Donald N. Zulli, residing at
125 Columbia Road, Enola, PA 17025, by depositing a copy of tile same in the United States
mail, certified, restricted delivery, return receipt requested. Service was complete upon receipt by
Donald N. Zulli on August 8, 2005, as evidenced by the attached green card with the article
number 7005 0390 0003 2632 4754.
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Carlisle, P A 17013
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I RECEIVEr)\
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lEY:'
JENNIFER CHRISTOPHER
(FORMERLY JENNIFER ZULLI),
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 95-5507
CIVIL ACTION - LAW
vs.
DONALD N. ZULLI,
Defendant
IN CUSTODY
ORDER
AND NOW, this (r- -It day of November, 2005, the Conciliator being advised
the parties have reached an agreement, the Conciliator relinquishes jurisdiction.
Respectfully submitted,
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JENNIFER CHRISTOPHER,
Plaintiff
v.
In the Court of Common Pleas
Cumberland County, Pennsylvania
Civil Action - Custody
DONALD ZULLI,
Defendant
No. 95-5507
Civil Term
Petition to Schedule Conciliation
1. The Petitioner is Jennifer Christopher. She is an adult individual currently
residing at 257 South Pitt Street, Carlisle, Cumberland County, Pennsylvania.
2. The Respondent is Donald Zulli. He is an adult individual currently residing at
125 Columbia Road, Enola, Cumberland County, Pennsylvania.
3. A Petition to Modify Custody was filed on July 21, 2005.
4. The Custody Conciliation was scheduled for November 10,2005.
5. The conciliation was cancelled because the parties thought they came to an
agreement.
5. Negotiations between the parties broke down and the parties were unable to
finalize an agreement.
6. Pursuant to Rule 206-2(c), Defendant's attorney of record, Max Smith, Esquire,
was contacted to seek concurrence. Mr. Smith no longer represents the Defendant in this
matter.
WHEREFORE, the Petitioner respectfully requests the court schedule a custody
conciliation in the above-captioned matter.
Date: .x /~/tJ( c
_ ,r'I.. '.. 11[',
(XR;"J[() IiI tf;L,
LAUREN MCHALE
Certified Legal/Intern (
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ANN 'ONAL -F X
LUCY JOHNSTON-WALSH
THOMAS M. PLACE
ROBERT E. RAINS
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
VERIFICATION
1 verify that the statements made in this Petition to Schedule Conciliation are true
and correct to the best of my personal knowledge and belief. 1 understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to
unsworn falsification to authorities.
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Date: ::'1. c~ I :\. c
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i CihAff.) (, I't (' <-
Lauren McHale
Certified Legal Intern
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JENNIFER CHRISTOPHER,
(formerly Jennifer Zulli),
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: IN DIVORCE
DONALD ZULLI,
Defendant
: NO. 95-5507 CIVIL TERM
PRAECIPE TO PROCEED IN FORMA PAUPERIS
TO THE PROTHONOTARY:
Kindly allow Jennifer Christopher, Plaintiff, to proceed in forma pauperis.
The Family Law Clinic, attorneys for the party proceeding in forma pauperis,
certifies that we believe the party is unable to pay the costs and that we are providing free
legal service to the party.
Date 14/ !cn-
~.,
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L C TON-W L
ANNE ' ACDONALD-FOX
Supervising Attorneys
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
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JENNIFER CHRISTOPHER
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
V.
95-5507 CIVIL ACTION LA W
DONALD N. ZULLI
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, _---.:r_hurs~~Febrll.'!':L16, 2006
.._' upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq.
, the conclliator,
at~h Fl'?(}"'.c::u..llI.berl"n<lC::()lIl1~c::o_u~th_ou.s~,~a_rlis~e_ on Thursday, March 23, 2006 at 9:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort wiil 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. Ail 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 Ahuse orders,
Special Relief orders, aud Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: ..JsI....__ Hubert X Gilr0-'>-Esq.__+r-li'4----
Custody Conciliator !.J'
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites Act of 1990. For informalion about accessible facilities and rcasonable accommodations
available to disabled individuals having business before the court, please contact our oftlce. A11 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, Pcnnsylvania 17013
Telephone (717) 249-3166
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JENNIFER CHRISTOPER,
Plaintiff
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IN THE COURT OF COMMO\\ PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
: NO. 95-5507
CIVIL ACTION - LAW
DONALD N. ZULLI,
Defendant
IN CUSTODY
COURT ORDER
AND NOW, this TKJ day of March, 2006, upon consideration of the attached
Custody Conciliation Report, it is ordered and directed as follows:
1. The Mother, Jennifer Christopher, and the Father, Donald N. Zulli, shall enjoy shared
legal custody of Nikolas A. Zulli, born September 23, 1993.
2. Physical custody shall be handled as follows:
A. During the school year, the minor child shall reside with the Mother during the
week and shall reside with the Father every weekend from Friday after school
until Sunday evening at 7:00 p.m.
B. During the summer months, the parties shall alternate custody on a week
on/week off basis, the date of exchange to be arranged between the parties.
C. The parties may share or alternate holidays as they agree.
D. The parties may modity the above schedule as they agree. Absent an
agreement, the above schedule shall control.
3. In the event either party desires to modity this Order, that party may petition the
Court to have the case again scheduled for a custody conciliation conference.
4. Pursuant to the agreement of the parties, the parties will execute all appropriate
documentation as required to allow Father to claim the minor child as a dependent on
his Federal income return in even numbered years and Mother to claim the minor
child as her dependent in odd numbered years.
Cc: ~x Smith, Esquire \
vMs. Tara Yutzy "
Judge
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JENNIFER CHRISTOPER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v
: NO. 95-5507
CIVIL ACTION - LAW
DONALD N. ZULLI,
Defendant
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF
PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following
report:
1. The pertinent information pertaining to the child who is the subject of this litigation is
as follows:
Nikolas A. Zulli, born September 23, 1993
2. A Conciliation Conference was held on March 23, 2006 with the following individuals
in attendance:
The Mother, Jennifer Christopher, with her student attorney Tara Yutzy of the
Dickinson School of Law Family Law Clinic
The Father, Donald N. Zulli, with his counsel, Max Smith, Esquire
3. The parties agreed to the entry of an Order in the form as attached which will replace
the Dauphin County Order entered at No. 2031-1996.
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Date: March ;; ~ , 2006
A
Hubert X.
Custody
/