Kula 08-11-11 P&A Final

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LAURENCE B. DONOGHUE, (State Bar No: 64031) LAW OFFICES OF LAURENCE B. DONOGHUE 28924 S. Western Avenue, Suite 205 Rancho Palos Verdes, CA 90275 TEL: (310) 548-4826 FAX: (310) 548-0759 EMAIL: LBD@ATTY.CA Attorney for Respondent, ELAINE KULA SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES CENTRAL DISTRICT
11 IN THE MATTER OF: 12 13
MARK KULA, Petitioner,
14 vs. 15 16 17 18 19 20 21 22 23 24 25 26 27
THE LAW OFFICES OF LAURENCE B. DONOGHUE 28924 S. Western Ave., 205 Rancho Palos Verdes, CA 90275 (310) 548-4826 (310) 548-0759
ELAINE KULA, Respondent.
) ) ) ) ) ) ) ) ) ) ) ) ) ) )
CASE NO. BD546371 Assigned to Hon. Randall C. Pacheco RESPONDENTS MEMORANDUM OF POINTS AND AUTHORITIES DATE: 08/12/11 TIME: 8:30 A.M. DEPT: 6
I. INTRODUCTION Petitioner defrauded Respondent into traveling from Illinois to California for the sole purpose of conferring jurisdiction in this State and he should not be rewarded for his fraud. Petitioner filed his Petition for Legal Separation six (6) days after Respondent and their triplets arrived in California and upon information had been planning to file for legal separation from Respondent for at least three months prior to that date (when Respondent and the children were
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KULA V. KULA - BD546371- DECLARATION OF ELAINE KULA MOTION TO QUASH AND DISMISS 1
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still in Illinois) and deliberately concealed this from Respondent so that she would join him in California. Petitioner and Respondent had been living apart for three months prior to the time he filed for legal separation because Petitioner accepted a new job in California. Petitioner moved to California in March 2011 and Respondent remained in Illinois with the parties three children until June 2011. The parties agreed that Respondent would join him in California after the children finished the school year and that they would live as a family in California. At no time prior to being served with separation papers (six days after she arrived in California) did Petitioner ever alert Respondent to the fact that he did not intend to remain married to her. It is clear why he omitted this fact she never would have agreed to move with him! She would never have uprooted the children from their home in Illinois and traveled across the country to California where the children have no friends, no family (other than Petitioner who travels 80-90% of the time for work) and no connection, let alone a significant connection. Petitioners divorce planning and fraudulent scheme should not be rewarded. It is clear that Petitioner planned for some time (and certainly knew prior to Respondent traveling to California on June 8, 2011) to separate from Respondent and that he concealed this from her for his own gain to have California hear this matter. In fact, when Respondent traveled to California on June 8, 2011, much to her surprise, and in contrast to what Petitioner promised, he did not join her and the children in the home that he had rented prior to her arrival (Respondent never agreed to this home nor did she sign the lease). Instead, he remained in a temporary housing apartment that he had been living in for the prior three months. This fact speaks volumes. It cannot be argued that Petitioner had no intention to leave Respondent. He lured her to California. He broke his promise to move in with her. And then he broke an additional (and most significant) promise to remain married to her. Again, he did so within days of her arrival. Contrary to Petitioners argument, that the children were present in California for six days does not confer jurisdiction over them and it does not defeat the plain fact that Illinois is the home
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state of the children. Illinois is the only state where the children have continuously resided since 2008. They have attended school in Illinois, have never attended school in California, and are currently enrolled in their same Illinois school to begin school again on August 24, 2011. Their doctors are in Illinois. Their church is in Illinois. Their friends are Illinois. Their classmates and teachers are in Illinois. Additionally, Illinois is the only state that has jurisdiction to resolve the parties dissolution of marriage. Respondents Petition for Dissolution of Marriage is pending in Illinois. It is undisputed that California does not have jurisdiction to dissolve the parties marriage (which is why Petitioner filed for legal separation). Petitioners Petition for Legal Separation should be dismissed because Respondent was temporarily present in the state of California under false pretenses and jurisdiction cannot lie under these facts. The issues of custody, child support, maintenance, and property division can most expeditiously be resolved in Illinois aside from the fact that it is the only legitimate forum under the law. The children are now back in their school district in Illinois with their friends and ready to resume school in approximately two weeks. The children are in their home state. Accordingly, the Service of Summons should be quashed and Petitioners Petition should be dismissed. Additionally, Illinois, not California, has jurisdiction over the child custody dispute.
II. UCCJEA GOVERNS DETERMINATION OF JURISDICTION OVER CHILD CUSTODY Respondent with Petitioner that generally questions of interstate jurisdiction regarding child custody are settled in California under the provision of the Uniform Child Custody Jurisdiction Enforcement Act (UCCJEA), Family Code 3400 et seq.; see also Wallace v. Superior Court (1993) 15 Cal.App 4th 1182, 1184.
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However, Respondent strongly objects to Petitioners contention that the only pertinent based on jurisdiction in the present case are as follows especially since Petitioner does not even cite Family Code Section 3421 in its entirety. Family Code Section 3421 clearly states: Except as otherwise provided in Section 3424, a court of this state has jurisdiction to make an initial child custody determination only if any of the following are true: (1) This state is the home state of the child on the date of the commencement of the proceeding, or was the home state of the child within six months before the commencement of the proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state. (2) A court of another state does not have jurisdiction under paragraph (1), or a court of the home state of the child has declined to exercise jurisdiction on the grounds that this state is the more appropriate forum under Section 3427 or 3428, and both of the following are true: (A) The child and the child's parents, or the child and at least one parent or a person acting as a parent, have a significant connection with this state other than mere physical presence. (B) Substantial evidence is available in this state concerning the child's care, protection, training, and personal relationships. (3) All courts having jurisdiction under paragraph (1) or (2) have declined to exercise jurisdiction on the ground that a court of this state is the more appropriate forum to determine the custody of the child under Section 3427 or 3428. (4) No court of any other state would have jurisdiction under the criteria specified in paragraph (1), (2), or (3). (b) Subdivision (a) is the exclusive jurisdictional basis for making a child custody determination by a court of this state. (c) Physical presence of, or personal jurisdiction over, a party or a child is not necessary or sufficient to make a child custody determination.
In The present case, Petitioner makes two errors in his contention: That FC Section 3421 is the only pertinent basis for jurisdiction in the present case; and Petitioners pronouncement of Family Code Section 3421 is two times what the Petitioner represents in his Point and Authorities.
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III. HOME STATE JURISDICTION FAMILY CODE SECTION 3421 A. CALIFORNIA IS NOT AND CANNOT BE CONSIDERED AS THE HOME STATE FOR THE MINORS.
Under FC Section 3421, California may exercise custody jurisdiction if either it is the childs home state, when the proceeding is commenced or was the childs home state within six months before commencement of the proceedings and the child is absent from California, but a parent or person acting as a parent continues to live in California (FC Section 3421). In the present case, neither qualifying option applies. As to the first option, the date the first pleading was filed was June 14, 2011. Petitioner concedes that on that date, the Court did not have jurisdiction over the children since they had not lived in the state of California for six months or in the county of Los Angeles for 90 days. Home State is defined as the state where the child lived with a parent or person acting as a parent for at least six consecutive months immediately before commencement of the custody proceeding; if the child is less than six months old, the state where he or she lived from birth with any of such persons. FC 3402(g); 28 USC Section 1738A(b)(4); Guardianship of Ariana K. (2004) 120 CA4th 690, 703, 15 CR3d 817, 825 [emphasis added.] In the present case, the children of the marriage did not reside in the State of California and could not call California a home state. The children arrived in California on June 8, 2011, five days before the commencement of the proceedings. Therefore, the children do not meet the first requirement for California to exercise Jurisdiction.
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As to the second qualifier, the children arrived in California on June 8, 2011, which was six days prior to the commencement of the proceedings. As of June 8, 2011, and up to and including June 14, 2011, California cannot be regarded as the childrens home state because, as argued supra, the children had not resided in California for six consecutive months. Therefore, the second qualifier cannot apply since, as of June 14, 2011, the date of the commencement of the proceedings, California did not qualify as a home state for the children. This case is distinguishable from In the case of In re Marriage of Diaz, 363 Ill. App. 3d 1091, 1097, 845 N.E.2d 935, 941 (2nd Dist. 2006), the Court found that neither Michigan nor Illinois was the home state of the child. In this case, as previously discussed, the home state is unequivocally Illinois. Moreover, even if the Court finds that there is no home state, the rationale and ultimate holding in Diaz, actually supports Respondents position that Illinois is the appropriate forum. In Diaz, the court ultimately held that Illinois was the appropriate forum to exercise jurisdiction because it had the most significant connection to the child. The court noted that the child received medical aid and food supplements from Illinois, that the mother attended counseling in Illinois and that she planned on attending parenting classes, obtaining independent housing for herself and [the child] in Illinois and that substantial evidence of [the childs] care, protection, training, and personal relationships exists in Illinois. Id. at 944. Here, the children were present in California for a period of days prior to returning to Illinois. They have no connection to California (other than their father who travels significantly for work) and there is no evidencing relating to the children in California. All of their doctors, records, friends, and information is located in Illinois.
B. ILLINOIS DOES HAVE HOME STATE JURISDICTIONS OVER THE MINORS.
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Respondent certainly concedes with California does not have home state jurisdiction over the minor children. The family, including the minor children, moved to the State of in February 2008, and since then have resided in Lake County, Illinois. Per Petitioners own Declaration under Uniform Child Custody Jurisdiction Enforcement Act (FL-105), the parties and the children moved to and resided at 22320 North Greenmeadow Drive, Killdeer, IL 60047 from July 2008 until June 11, 2011, three days before the commencement of the proceedings. Respondent contends that the children were in California from June 11, 2011 to June 27, 2011, which constitutes a period of temporary absence from the State of Illinois. Then the minors visited their maternal grandmother in the state of New York, from June 27, 2011 to July 19, 2011, constituting a second period of temporary absence from the State of Illinois. On July 19, 2011 the children came to California until July 25, 2011, constituting another temporary absence from their home state of Illinois. On July 25, 2011, when they returned to their home state in Illinois at their home state address of 22320 North Greenmeadow Drive, Killdeer, IL 60047. However, since their Illinois residence was in the process of being sold, Respondent secured a new residence at 1223 William Drive, Lake Zurich, IL 60047, where they currently reside. It is Respondents contention that Illinois has been and continues to be the home state of the children. IV. PETITIONERS ARGUMENT WITH REGARD TO TEMPORARY ABSENCE LACKS RELEVANCY AND MERIT AS TO THE ISSUES BEFORE THIS COURT. The law Petitioner relies on in Family Code Section 3402(g) and Marriage of Nuri (2009) 176 CA4th 478, 492 has to do with the meeting of the time requirement for home state determination. Both Petitioner and Respondent have conceded that California does not have home state jurisdiction. Therefore, the issue of temporary absence is irrelevant for any purpose other than home state determination for the State of California.
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Petitioner offers no argument or legal authority for what the definition of temporary absence means, or what impact, if any it has on this Courts determination of California being the home state. There is legal argument that temporary absences from the state of Illinois are counted in consecutive requirement under Family Code Section 3402(g). For that argument, FC 3402(g) does apply in that they were present in California for a small amount of time which amounts to days does not result in a finding that they forfeited a home state in Illinois. In the present case, Respondent contends that the children were in California from June 11, 2011 to June 27, 2011, which constitutes a period of temporary absence from the State of Illinois. Then the minors visited their maternal grandmother in the state of New York, from June 27, 2011 to July 19, 2011, constituting a second period of temporary absence from the State of Illinois. On July 19, 2011 the children came to California until July 25, 2011, constituting another temporary absence from their home state of Illinois. On July 25, 2011, when they returned to their home state in Illinois at their home state address of 22320 North Greenmeadow Drive, Killdeer, IL 60047. However, since their Illinois residence was in the process of being sold, Respondent secured a new residence at 1223 William Drive, Lake Zurich, IL 60047, where they currently reside. Therefore, it is clearly from the law and the fact that Illinois has been and remains the home state of the minor children.
UCCJEA clearly requires a Court to decline its jurisdiction if the jurisdiction has been invoked as a result of a party engaging in unjustifiable conduct. 750 ILCS 36/208(a). V. PETITIONERS RELIANCE ON THE CASE OF IN THE INTEREST OF KAYLEE LYNN-MARIE BRILLIANT, A CHILD 86 S. W.3D 680 (Tex.App.El Paso 2002) IS CLEARLY DISTINGUISHABLE, ILL-PLACED AND MISLEADING.
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Petitioners reliance on the Texas Case of In the Interest of Kaylee Lynn-Marie Brilliant, a child 86 S.W.3d 680 (Tex.App.El Paso 2002) is clearly distinguishable, ill-placed and misleading. First of all, Brilliant is a Texas case, and is therefore not binding on this Court. Secondly, in both the facts and the law, Brilliant is clearly distinguishable. Brilliant relies on the following factual findings: 1. That there was little evidence provided by mother Massachusetts (Illinois in our case); 2. That Father had significant connection to Texas (California in our case) other than mere physical presence; 3. That Texas (California in our case) was the repository of substantial evidence concerning the childrens present and future care, training, and personal relationships; 4. That at the time of commencement of the Texas proceedings (California in our case), the Texas Court had jurisdiction over the issues of custody and visitation. None of these facts hold up in the present case. of the childs connection to
Secondly, in Brilliant, the court found that there was no home state. Arguably, the home state in this case is Illinois. Still further, if the Court determines that there is no home state, the facts of Brilliant do not advance Petitioners argument as they are completely contrary to the facts here. In Brilliant, the parties agreed to move to Texas for a common purpose and there was no fraud. In fact, unlike here, it was the mother that decided, unilaterally, to change the plan and return to Massachusetts forty five days after arriving in Texas because she simply did not like it there. Here, however, there was no joint meeting of the minds as to the purpose for the move. Respondent thought she
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was traveling to California to continue life as a family, whereas, Petitioner planned to separate and thereafter divorce her moments after her arrival. Petitioner in this case filed the Petition for legal separation on June 14, 2011, a mere six days after Respondents arrival in California. It would seem obvious that the time that it took Petitioner to select an attorney, meet with an attorney, retain the attorney, prepare the necessary pleadings for filing, and have them actually filed would have taken at least six days. The obvious conclusion it that Petitioner moved to California already intending to break up his marriage, even before Respondent arrived in California. Also, in Brilliant, the children were present for 45 days in Texas whereas they were only present in California for six days preceding the filling of Petitioners action. Significantly, however, the most crucial distinction between Brilliant and the facts here is that the child in Brilliant had a significant connection to Texas other than mere physical presence, and, based on the record before us, Texas was a repository of substantial evidence concerning her present or future care, training, and personal relationships. (emphasis added). The only evidence of a connection to Massachusetts was that the childs medical needs were being neglected. Conversely, here, there is no information, let alone a repository of information concerning the children in California. All of the information concerning the children is located in Illinois, where their mother lives and where they have lived since 2008. As Brilliant clarifies, Petitioners physical presence alone in California is not enough to confer jurisdiction.
VI. SIGNIFICANT CONNECTION AND SUBSTANTIAL EVIDENCE LAW IS CLEARLY FALLS IN FAVOR OF THE RESPONDENT.
Family Code Section 3421(a)(2)(A) and (B) provide as follows: (a) Except as otherwise provided in Section 3424, a court of this state has jurisdiction to make an initial child custody determination only if any of the following are true:
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(1) This state is the home state of the child on the date of the commencement of the proceeding, or was the home state of the child within six months before the commencement of the proceeding and the child is absent from this state but a parent or person acting as a parent continues to live in this state. (2) A court of another state does not have jurisdiction under paragraph (1), or a court of the home state of the child has declined to exercise jurisdiction on the grounds that this state is the more appropriate forum under Section 3427 or 3428, and both of the following are true: (A) The child and the child's parents, or the child and at least one parent or a person acting as a parent, have a significant connection with this state other than mere physical presence. (B) Substantial evidence is available in this state concerning the child's care, protection, training, and personal relationships.
Significant connection is not tied to events occurring before or at time of action is commenced. Significant connection jurisdiction is unlike home state jurisdiction in that it is not tested by facts or events occurring before or after the time the action is commenced. The UCCJEA tests significant connection jurisdiction by looking at the evidence before the Court when the
jurisdictional determination is made. Haywood v. Super.Ct. (2000) 77 CA4th 949, 955, 92 CR2d 182, 1987 (UCCJA significant connection jurisdiction.) Under such an analysis, when there is no home state, the Court would be required to determine which of the two states has a more significant connection to the children and in which of the two states there is substantial evidence concerning the childrens care, protection, training, and personal relationships (Fam.Code 3421(a)(2) and 750 ILCS 36/201(a)(2)) and again, the answer is clearly Illinois. As previously discussed, the children have not consecutively resided in California for six (6) months or for any significant period of time. In fact, other than the few days that the children spent in California prior to Respondent being served, and a few days in July, they have not been present in California at all.1 The Court in Sareen unequivocally held that nine (9) days in a state is a miniscule amount of time [and] does not come close to establishing the
The children traveled to visit Respondents family with Petitioners agreement and subsequently returned to Illinois with Respondents mother.
1
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connection to the state required by the UCCJEA for the exercise of custody jurisdiction. Id. Thus, California is not the childrens home state. In ascertaining which of the two states has a more significant connection with the children and in which state there is substantial evidence concerning the childrens care, protection, training, and personal relationships, Illinois is clearly the state where jurisdiction is proper. The children were merely present in California for a period of days (under false pretenses), they never attended school in California or camp in California or any other organized activity in California, they never resided in a permanent residence (during their brief stay in California the children slept in a home leased by Petitioner (Respondent did not sign the lease)), they have no doctors in California, no friends in California, no family in California (other than Petitioner who travels 80-90% of the time for work). In contrast, the children have had continuous ties and connections to Illinois since 2008. The children have attended school in Illinois since 2008, they have been active in their Illinois church since 2008, the male children have been active in their local Illinois Boy Scout Troops. Furthermore, Respondent has family in both Chicago and Peoria who are close with Respondent and the children, and all of the childrens friends reside in Illinois. Respondent resides in Illinois and she is and has always been the childrens primary caretaker. Throughout the marriage Petitioner has traveled for significant periods of time and she has always been the one to provide them with care. This is a clear cut case where a woman and her children were duped into traveling to California for a very short period of time. Both the fraud and the short time period that they were present in California should prevent any finding that the children are without a home state, or that the home state is any other state than Illinois.
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VII. CALIFORNIA IS AN INCONVENIENT FORUM FOR THIS CHILD CUSTODY DISPUTE Family Code Section 3427(a) provides that a court can decline to exercise its UCCJEA jurisdiction at any time if it finds it is an inconvenient forum under the circumstances and that another states Court is a more appropriate forum to make the custody determination. In the present case, aside from the fact that the childrens home state is Illinois and it is therefore the only appropriate forum to exercise jurisdiction over the children, this action should be dismissed due to forum non conveniens. It is Illinois, not California, that has subject matter jurisdiction to dissolve the parties marriage (this is not disputed Petitioner filed a petition for legal separation, as opposed to divorce, for this reason). Respondent is residing in Illinois and her Petition for Dissolution is pending in Illinois. As such, it is most appropriate that the entire case be heard in Illinois. Of the relevant factors outlined in the UCCJEA regarding inconvenient forum, they all weigh in favor of Illinois as the appropriate forum. Specifically, the factors are: 1. Whether domestic violence has been an issue and what state could best protect the parties and the children; 2. The length of time the children have resided outside of the state; 3. The distance between California and the state that would assume jurisdiction, Illinois; 4. The relative financial circumstances of the parties; 5. Any previous agreement of the parties as to which state should assume jurisdiction; 6. The nature and location of the evidence required to resolve the pending litigation, including the testimony of the child;
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7. The ability of the court of each state to decide the issue expeditiously and the procedures necessary to present the evidence; and 8. The familiarity of the court of each state with the facts and issues in the pending litigation. Ann.Cal.Fam.Code 3427(b) and 750 ILCS 36/207(b). In this case, the children solely resided in California for a period of six days prior to the commencement of the action. Petitioner is the sole wage earner (and earns a substantial income upon information of at least $500,000 annually) and is therefore clearly in a better position to travel to Illinois to participate in these proceedings, than Respondent would be to travel to California. Respondent is a full-time homemaker and housewife with no income and has virtually sole responsibility to care for the children. It would place an enormous burden on her to be required to travel to participate in these proceedings. As discussed above, all of the evidence pertaining to the children is in Illinois where they have continuously resided (with the exception of a brief absence as a result of Petitioners fraud) since 2008. Evidence of the childrens schooling, their teacher evaluations, their progress reports, their report cards, their doctors records, their church involvement, their mother, all third party witnesses with knowledge regarding the parties and their children, and the children themselves are all located in Illinois. Petitioner is the only California witness that can testify. Since Petitioner travels frequently for his work commitments it would not be inconvenient for him to come to Illinois. Other than
Petitioner, no other witness or physical evidence is located in California. Since the majority of the witnesses including the children reside in Illinois and all of the physical evidence is located in Illinois, it would be much more cumbersome to hold the evidentiary hearings and trial in California since almost all of the evidence is outside the subpoena power of a California Court. Since the inconvenient forum factors heavily favor jurisdiction in Illinois, the UCCJEA requires that the child custody proceedings in California be stayed upon the condition that a child custody proceeding be promptly commenced in another designated jurisdiction, in this case, Illinois. Ann.Cal.Fam.Code 3427(b) and 750 ILCS 36/207(b). However, because such an action
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has already commenced through the filing of Respondents Petition for Dissolution, it is appropriate to dismiss Petitioners action in California. It is further argued that regardless of what the Court decides as to home state and significant connection jurisdiction, a UCCJEA inconvenient forum stay is discretionary with the forum Court (Family Code Section 3427(a), the Court may decline to exercise its jurisdiction. Marriage of Fox (1986) 180 CA3d 862, 870, 225 CR 823, 827. Also, before determining whether it is an inconvenient forum under the UCCJEA, a California Court must consider whether it is appropriate for another states court to exercise jurisdiction. For this purpose, the California Court must allow the parties to submit information and shall consider all relevant factors. Family Code 3427(b).
VIII. CONCLUSION For all foregoing reasons, Respondent respectfully requests that the Court grant the Respondents relief sought and quash service of the summons and dismiss the Petition in its entirety with prejudice
Date: August 11, 2011
_____________________________ Laurence B. Donoghue, Esq.
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Kula 08-11-11 P&A Final

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11 IN THE MATTER OF: 12 13

MARK KULA, Petitioner,

ELAINE KULA, Respondent.

B. ILLINOIS DOES HAVE HOME STATE JURISDICTIONS OVER THE MINORS.

Date: August 11, 2011

_____________________________ Laurence B. Donoghue, Esq.

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Kula 08-11-11 P&amp;A Final

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11 IN THE MATTER OF: 12 13

MARK KULA, Petitioner,

ELAINE KULA, Respondent.

B. ILLINOIS DOES HAVE HOME STATE JURISDICTIONS OVER THE MINORS.

Date: August 11, 2011

_____________________________ Laurence B. Donoghue, Esq.

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Kula 08-11-11 P&A Final

Kula 08-11-11 P&A Final