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Home My WebLink About01-2382 FX ". - '1 . Of. Of. ;f.;f. ;f.;f. ;f. . ;to ;to ;to ;to;tO ;to ;to IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNA. STATE OF LINNAYA M. KENYl;:N. Plaintiff No. 2001 2382 VERSUS OJAD M. KENY<JiI. ~endant . . . DECREE IN DIVORCE ;:J;-~:()( t.J1I/. O~~ ~ , IT IS ORDERED AND . . . . . . AND NOW, DECREED THAT Linnaya M. Kenycn, PLAINTIFF, . AND <:bad M. Kenvon. DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAiNS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . None . . ATTEST: ~ J. ~~PROTHONOTAR' . :f.;tO ;to;tO:f. .. . . ;to:f.OF.:+;;tO OF.;tO :F.;tO ',- -.,,-,.,.,-. .,.' r 'I '- -,,-- " ~"I~~" - :;,_,.,-,r.h.;, F~" -I' l--"r '-", :F.;tO;tO;f.~lf. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . t' ."" i~~~:'~ ~...-4 - &oIt'~"""'~.i"~~~~M~illiI~h@i~:!!'iI1i~~-~;'~ >~.~_._" " ~~"~,' ",.','. /{J,30! W ~ ~ ~ ,J:::: L /t' :J.,tJ/ 71~ ~ z cfI7' I~".." _ ~J" ." J ", " . .~ ~ ~;i I.: I: !J II H i.i :: " ii !' 'i .'''':''''i " APRllZOllIt;l? Linnaya M. Kenyon, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN CUSTODY NO: 2001 - 238;1... ~ I.t-<- v. Chad M. Kenyon, Defendant CUSTODY AGREEMENT AND ORDER r; 3 -r. C'lc'-' TillS AGREEMENT, made this ?-, day of 'lI( V't ,2001, between Linnaya M. Kenyon, hereinafter Mother, and Chad M. Kenyon, hereinafter Father, concerns the custody of their child, Kaitlyn D. Kenyon, born December 12,1997. Mother and Father desire to enter into an agreement as to the custody of the child. Mother and Father agree to the following: 1. Mother shall have sole legal custody of the minor child. 2. Mother shall have primary physical custody of the child. 3. Father shall have partial physical custody of the child as follows: a. One weekend per month from 9:00 p.m. Friday until 9:00 p.m. Sunday. b. Mother and Father will share transportation, with the person beginning his or her custodial period having responsibility for picking up the child. 4. Holidavs. The following holiday schedule shall supersede the regular custody schedule. At the end of the holiday period (as set forth below), the regular custodial schedule shall resume. Mother and Father agree to share custody of the child on the child's birthday, Christmas, Mother's Day, and Father's Day as follows: a. Birthdav/Christmas. Because the child's birthday is near Christmas, the following custodial schedule provides for both holidays each year. 1 -~ , "I -r- '._,' "'.-[., ~""""-" . Birthday/Christmas will be divided into two time periods. The first period (Period "A") will be from 9:00 p.rn. on the Friday night before the child's birthday unti19:00 p.rn. on the Sunday following the child's birthday, including one week. The second period (Period "B") will be from 9:00 p.rn. on the Friday before Christmas Day until 9:00 p.rn. on the Sunday following Christmas Day, including one week. Father will have custody of the child during Period A in even numbered years and during Period B in odd numbered years. Mother will have custody of the child during Period A in odd numbered years and Period B in even numbered years. b. Father's Dav. Father will have custody on Father's Day Weekend from 9:00 p.m. Friday until 9:00 p.m. Sunday. c. Mother's Dav. Mother will have custody on Mother's Day Weekend. 5. Vacation. Father may have physical custody for two 2 -week periods during the summer, times to be agreed upon by Mother and Father. Father must give 30 days notice to Mother. Other than these vacation periods, Father may not remove the child from the Commonwealth of Pennsylvania unless he gets written authorization from Mother. 6. If Father takes the child anywhere other than his residence for extended periods of time during his custodial periods, Father must give Mother the location and phone number where the child can be reached. 7. Father will provide all transportation relating to the vacation periods. 2 -,"" ~ .u i - .,. 1-, 'Ll ,If, 8. Neither party will be intoxicated from alcohol or drugs while in the presence of the child. If Father is charged with any alcohol or drug related offense relating to a time that he has or had physical custody of the child, Father agrees that his rights to unsupervised custodial periods under this Agreement and Order shall immediately terminate. It: this occurs, Father's visitation periods with the child shall be supervised by a person mutually agreed upon by the parties until Father has successfully completed an alcohol or drug treatment program. 9. Mother and Father shall be entitled to reasonable telephone access with the child while the child is in the other's custody. 10. The parties shall keep one another advised of their current address and telephone number. 11. Father and Mother will inform each other of medical care the child needs or receives while in the other parent's care. Father and Mother will notify the other immediately of medical emergencies which arise while the child is in that parent's care. 12. Neither parent will do anything which may estrange the child from the other party, or injure the opinion of the child as to the other parent, or which may hamper the free and natural development of the child's love and respect for the other parent. 13. Father understands that if Mother moves out of Cumberland County, this Agreement will remain in effect. 14. Father has been informed and understands that the Family Law Clinic represents only Mother's interests in this matter. He has been advised that if he wants legal advice on this matter, he must obtain his own attorney. He understands this and has chosen to proceed without counsel. 3 1';:.''''1 I'" 11 ,-, I , - 15. The parties intend to be bound by the te!1l1S of this Agreement and intend that this Agreement be entered as an Order of Court. ~~~ Chad M. nyon c;t~~..~ Li aya M. eny ?~s.~ gy S. Hale Certified Legal Intern :;2Lt4- hornas M. Place Robert E. Rains Ten L. Henning SUPERVISING ATTORNEYS FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 1 ~ O~ER AND NOW, this ,;~S day of ~ ,2001, the foregoing Agreement is approved and entered as an Order of Court. Date: 4~(' .2001 .y ~ 1. ':'ti<:~ ,",~ '"~ _ ,'~, __ 11 !'l' "\ ~,'" '.lJ "~ ~~ "" __,,~,~~.,<,_.,~~ = _~_ _. =_~ n,=_~ "'I \IlN\fA1ASNN3d AlNnOO O~j!fl!:l38~~nj 8'1:SWd SZHdVIO Al:lIflO:'!(!HlGJe! ::'.Ii "0 30f;j~()-{Jil.lf..j,. - "'liISlIlf'!IlIm "~"" _"",~,...,.ll!If.4~~"'__ ~U;J!lI!I(llf{llllll/lllJ!;l!ft' ~ _ !ffl,S~\_!",_~~~~~['ll-,T':,*~"';f'9"'"00/"'"""(i\'--""-'~"';\<i'"-7"''''''+'~'':''_;';~0~'';jIli;'i''in1!f\!'Z~~)'I;''fil'~'@jr'''''''_~l~~F!',~~~ {I) -'1' APR 2 4 ZOOtOP LINNAYA M. KENYON, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY : NO. 0 1- J 3~:L CIVIL TERM CHAD M. KENYON, Defendant NOTICE TODEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your child. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITmS 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. "'''''''f'" -'", '1!~; I H'I l! '" -;- , "~~.~ LINNAYA M. KENYON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE AND CUSTODY CHAD M. KENYON, Defendant NO. 01- ,z31',l. CIVIL TERM DIVORCE COMPLAINT WITH CUSTODY COUNT The plaintiff, Linnaya M. Kenyon, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce and custody: COUNT I DIVORCE lJNDER 23 Pa.C.S. ~~ 330Hc) and 330Hd) OF THE DIVORCE CODE 1. Plaintiff is Linnaya M. Kenyon, who currently resides at 338 B East North Street, Carlisle, Cumberland County, Pennsylvania 17013, since January, 2000. 2. Defendant is Chad M. Kenyon, WhD currently resides at 18 North High Street, Newville, Cumberland County, Pennsylvania 17141, since February, 2001. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on September 12, 1996, in Duval County, Florida. 5. Plaintiff and defendant have lived separate and apart since November, 2000. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 1 n"l : .=_ -~ " - 'I'~' - -: 'I I 1"'11 "-~ , ~, 8. 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 cDunseling. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. COUNT II CUSTODY 9. Plaintiff repeats and realleges paragraphs 1 through 8, as if fully set forth herein. 10. Plaintiff seeks custody of the following child: Name Present Residence Date of Birth Kaitlyn D. Kenyon 338-B East North Street 12/12/97 (3 years old) Carlisle, P A 17013 The child was born within wedlock. The child is presently in the custody of Linnaya M Kenyon, who resides at 338-B East North Street, Carlisle, PA 17013. During the past five years, the child has resided with the following persons and at the following addresses: Person Addresses Dates Linnaya Kenyon Kimberlee Rabenstein (mother's sister) Jason Rabenstein (mother's brother-in-law) Ethan Rabenstein (mother's nephew) 338-B East North St. Carlisle, P A 17013 8/00 - current 2 """t- .,. ~I - 1', -'-",- ~- Linnaya Kenyon 338-B East North St. 1/00 - 8/00 Chad Kenyon Carlisle, PA 17013 Linnaya Kenyon 409 Sheely Lane 5/99 - 1/00 Pamela Siegman (mother's mother) Mechanicsburg, P A Amy Doolittle (mother's sister) Chad Kenyon Jacksonville, FL 11/98 - 5/99 Linnaya Kenyon Amy Doolittle Chad Kenyon Tampa, FL 5/98 - 11/98 Linnaya Kenyon David Siegman (mother's brother) Chad Kenyon Jacksonville, FL 12/97 - 5/98 Linnaya Kenyon 11. The relationship of the plaintiff to the child is that of mother. She is married. She currently resides with the following persons: Name Relationshin Kaitlyn Kenyon Daughter Kimberlee Rabenstein Sister Jason Rabenstein Brother-in-law Ethan Rabenstein Nephew 12. The relationship of defendant to the child is that of father. He is married. He currently resides with no other persons. 3 ,'~" _ ~. . 1 -~--'-"l ~ -~,- ~I- -j ~-: ,I 13. Plaintiff has not participated as aparty or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff has been primary caretaker of the child since birth; b) Plaintiff is better able to provide a home with adequate moral, emotional, and physical surroundings for the child, whose best interests would be served by an award of primary physical custody to the plaintiff. c) The parties have agreed to a custody arrangement, as set forth on the Order attached to this Complaint. 15. Each parent whose parental rights to the child has not been terminated and the person who has physical custody of the child have been named as parties to this action. 16. Plaintiff and Defendant entered into an Agreement as to Custody on April 22, 2001. The Agreement provides that Plaintiff shall have sole legal custody of the child. Plaintiff shall have primary physical custody and Defendant shall have periods of partial custody of the child as specified in the attached Agreement. The parties would like the Agreement to be entered as an Order of the Court. 4 ,",Jl _"_. i ,_e, -'t I f~- , !-1. I" " , WHEREFORE, plaintiff requests the court to grant to her sole legal and primary custody of the child and enter an Order in the form attached hereto. Date:~ ;~. plJl ~1~'~ Certified Legal Intern ~ L/:; L S M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys --.... FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 5 ,';,. ~~ 1 ., i -,"'. . -1-1 '";Ir"l , I ='- VERIFICATION I verify that the statements made in this Divorce Complaint with Custody Count 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 unswom falsification to authorities. Date: ~ L"""-.)t) \ , Linnaya M. Ken 6 -"':r.~ ~ I" -. j'! 111 I' ~" .' /'~"'.." , . .:: -~ ?~ ....... 6 (' D. ~ ~ ".IfJ[Iql !""",~._,R ""'~- ,," ,,~ " -- _ _~, N''''' ,.,<,,",",~m -.<< --,,~-~, .~ .""-'r-"~~'--" '"V"< ~" ."~ 0 c:::> 0 C " s: """ ~::;:J -uro -0 ri1 ~~-d m9J :;0 Z N -""jr.,. zS; i5'? ~"- eN -"- _..0 kC) -0 5=H ~o :x z~ 5>g r:.- ~ ~ ::::> :iJ 0:> -< ~ f '<l jJ " -p .,. <><J 7'\ ,:,", a- " ~ i3 d l J,i! .i\ffi'l~'lT'l1'ir._IjI;I~~~f!Ql~mJ;W~ffl!rnr'""1~i'>~,S:V"'F:~:;~'!/;i'1"J,,,[,iIit:~~~~~1\<>Ji!#'~~if~~~~~~~!w;i!'!!~~J~~Ijl!ljtlli'i1~~~1i~ : IN THE COURT OF COMMON PLEAS OF LINNAYA M. KENYON, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 01-2382 CIVIL TERM CHAD M. KENYON Defendant PROOF OF SERVICE Understanding that the making of any false statement would subject her to the penalties of 18 Pac C.S. ~4904 (relating to unsworn falsification to authorities), the undersigned verifies that the Family Law Clinic mailed a true copy of the Divorce Complaint with Custody Count on the Defendant by placing the same in the U.S. Mail, certified no. 70993400001849969657, restricted delivery, return receipt requested, postage prepaid, on the 23rd day of April, 2001 addressed as follows: Chad M. Kenyon 18 North High Street Newville, PA 17141 Sender's receipt no. 70993400001849969657 is attached hereto and incorporated by reference. On or about 10th day of May, 2001, green return receipt no. 70993400001849969657 was delivered to the Family Law Clinic, bearing the signature of Chad Kenyon and showing a date of service of May 3, 2001. The return receipt is attached hereto and incorporated by reference. 5 ~ 01 1 er ar son ertified Legal Intern F AMIL Y LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 Dated: ,",,;' . ~ ';rT,_ , i --"'::'^; I' :1' -" 1, II [' , ~ i j 'I :i ~i '!:~~.... . -'-"~- " -~ . . , " " ~ , "",~,,-, - ,-. -', - _<7_""~_'" ''f.' , ~_~.><; It,, o ~. ..:-:::: -Of-f' nlr-li z:~. ."7,.... /._~ (jJ ~'::- ~C. ~~; ~J. ~ '_C> C:;J "-- ;7;1-""1 C .,,-.1 - ~I ;-...) 1._0 ~~i ~ _0' _, ~~-~Ii1;>II!'lK:; __ m1W,~\1!t[fj~~!l" - - 4J1l T~: ___~_' Jf~.~~~'''5'''''''1 f:--~' t, _ _ e, ':';:li'C31 ~" '. ~7\ ,.... . ,'_, ~__ \: ::;i, ':~i" _,_ ,:' 'rAI", :-.--~ Item 4'~, llWM~d'i:!eIl\flll'Y Is desired. . Print your name and ~ddress on tha reverse $0 that we can return the card to you. . Attach this card to the back of the maiipiece, or on the front if spsce parmits. 1, Article Addressed to: D. Is denvery addres nt from Item 1? If YES, enter delivery address below: CJ Agent CJ Ad<lressee CJ Ves CJ No OIAD M KmYW 18 MJRlH HIGRJr :i'~'l' NEmVILLE PA 17141 Oe~ver to addressee oni,,: 3. ServiCE!l Type I. Certified Man CJ Express Mall [J Registered Cl Return Receipt for Merchandise . CJ Insured Mall D C.O.D. 4, Restricted CeUvery? (Extra Fee) a Yes 2, Artlcle:N~mbel'j(Copy: ~mjser!ce i~etJ) j)' -.,:,',.... "16,\'\' ~4bb'ddi'iS '4.~"I'~'<1(,;C::;1' PS Form 3811, July 1999 Domestic Return Receipt 102595-99.M.1789 r'- 1.11 ..J:I 0- ..J:I 0- 0- '" Postage $ ,5S /, qP ;. $'0 3.;;'0 Postmark Here Certified Fee -a .-'l CJ CJ Retum Receipt Fee (Endorsement Required) Bestricteci Delivery Fee (Endorsement Required) Total Postage & Fees $ 7-1 S CJ CJ .:::r- Recipient'S Name (PlealJe Print Clearly) (to be completed by mailer) m ~ '"y>-l. ~.~...___.__.___..__......__...___.. 'streEi(Apt. -No.;-or po-sox-f.JO:-;;..h1.t ~ ~ /~ ~ 4!<f,.____.__________,_______________________.___.____ :2 'Ciiy,-Si'ie~~ 11#:1 /'7.)tf). , ill . -'1-'<. r; LINNAYA M. KENYON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE CHAD M. KENYON, Defendant : NO. 01-2382 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~~ 3301(c) of the Divorce Code was filed on April 23, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. 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 8 \ \ 6 \ 5 \ " Linnaya M. K " ',_e:'_~J---. ~-: --~'l'~_:::""_"'-~I' 'mH''_',__ -- ":"-"-.-r--r~<J' , '," ':_c '. '. -,-., . __ _'-or '~.""" . '"" _,~ - 0- I ' ~ , "" ",c'-' _:'\~j_"L ...."..:~J,-" - ~- ~.~ I - o ,;;;; ,~, -ufJ3 Q)L! zf~-- (l) ~ -':' ~~; 5~2 .c:" -" -,( c' ):;tl> c::: 0"")- r'.J f'~ c~ :".) '".,~~'" .' ,A_, ---:i:::,,"' ~ 1.) rf! ,l!M~~~~lJi!~."lli~~~UP!~~_ ~,IU_,q i _~, ,'"'~_ ;?,__,:.,-:,,,_,;~_~.:; ;.1 LINNAYA M. KENYON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 01-2382 CIVIL TERM CHAD M. KENYON, Defendant WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property , lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. " I verify that the statements made in this affidavit are true and correct. 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 9 \ \ B \ {) \ , 'T -, 'C, t,~oC_"_",~"~_"C -,- "-""--,_:";--'.--. -~ ','IT:' t-: "---"1:-'"' , -~'" -" -" ,- ,; -, 'j7'l '-', r!' , _,_ .'__H _,,_,_,,_. __ , _ _1 . ,_C~i~ =- -'-Ji'"."'"'! .^ ,_~_'_' *_,.,__",___~-_. - ,~J "';': "--~-" .~_ 'f~, '1"1"""~- () C -:? -v 0_" [~-W,- ..i::. "~T zi s.~ ~ ):;: '~'. "'?t, 5~f~ L ~ " -"~ --j :~ :n ", " i'''. _.,C.l "- , C :" ('J ~~! :J:J -< "" oEJQ 'ffl"F".",.~.~,_t.~~:"_~'ftil.Ilfl~~M:!!"~~~~~~'Im"",",:"rI4_l;._ _ '_" .,.,) LINNA YA M. KENYON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 01-2382 CIVIL TERM CHAD M. KENYON, Defendant AFFIDAVIT OF CONSENT I. A Complaint in Divorce under ~~ 330l(c) of the Divorce Code was filed on April 23, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verity that the statements made in this affidavit are true and correct. 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 Pl>/k!e>/.o \ efendant "T_j ~,.- ,- ",".'-,,"" ___~," _, ,':":0 ~J'T":' c, I ,~""" ',~~ _~_~_, <c. f' I_ ., "!~_'_ ,":,,', ,''__ .'"F ',,-- J I ';'1 "~- !=r> p,> '.' ~r>~ C' ',-, '~'-' L"" .' -', ~~ o <;;~ .c: u,;";-~ n~l_G::': ~~S~ , / ~t:: ~2 d':" -, -< ".~ c:' "->-. ,- cc, :-"0 l~" r'<l -., (::) '"' ' .;IDlj~Jf~,.",!Q:~~~I$WMlP~4tt'i~!!J!11~'1q,,,,,,,,,,_~,~,",,,~~!"'f'_~~!:t'"~~~"~"~.l~'!!!!!~H LINNA YA M. KENYON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 01-2382 CIVIL TERM CHAD M. KENYON, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ll3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a fInal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is fIled with the prothonotary . I verify that the statements made in this affIdavit are true and correct. 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 q 8'" /.Qrc/O { c~ ~, 1 "--'"'~-' ,- ,,- -, .".- ,. :-!'~::>-I~-"-'''"'''h-+r~''l:~~'~--, ,,--'_,- --IJ'l"'-'",'_ ,,-;-, ---,~.. " -- . , ",_,m."cp,~_, "". ,_ '11:,:_, ~, ~~ 0 C') C."'; C 1 ~.:... '~ " G' rn{r-: 7') ~~. ,""J ..f,: r::::: C '''T) .-, ..::--- ..., ";,..' (-- c. C ,". --' -< c::.' ~~'" 1...~~~i~ij!J~~ll~:!~'I\'i\~~~~~.",.,~~~,<:.,~,W?'~ -"~,~;: .,--,- LINNA YA M. KENYON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE CHAD M. KENYON, Defendant : NO. 01-2382 CIVIL TERM Certificate of Service I, Debra Hart Munchel, Certified Legal Intern from the Family Law Clinic, hereby certify that I am serving a true and correct copy of the Praecipe to Transmit Record and the Vital Statistics forms, in the above referenced case, on the following individual, at the following address, by U.S. Mail, postage prepaid, this 26th day of September, 2001: Chad M. Kenyon 730 Silverleaf Court, Apt. F Glen Burnie, MD 21061 ~oOJ" ~.-l<: ...(Y\ 1 ~~ Debra Hart Munchel Certified Legal Intern '~. ! .-, ~-'-"'--""- '_T- '-, --"-_:'-:~"':"~:_-:?'_,_'-:' -T~-:--';'''~Jr'''':c:~',.!'''':'''1'' ,","',.-, -" ----1-':- -"1"1,,'- ",,-, "-""c' c,'_'-'7';~'.~<__ ,., M r__"'~ .- _ ,~.- ,--" ,,"," ,,'t- "',- [1tJ_1 _ ,_ ~= ~a o ~;; :YJr7':; Uh;-:, ~'!:~_i !~i~ ....-.....-. ~~. :< T ~~:) ~fl {C IlIMII Ulll"urr c:~- '-, (."1 ,-'1- ~lj ;'\) [,,-, .~X",~"'7"~~,__",~"_~,,,,,~_,,,,,,,!,,~iM1JIJ~,*,,ilf/)!;~~II,M~~,:j,~~,(Ji~~~J"!llJI\,~n~, -1 )1 LINNAYA M. KENYON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE CHAD M. KENYON, Defendant : NO. 01-2382 CIVIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of the Affidavit of Consent and Waiver of Notice forms signed by the plaintiff on the defendant, Chad M. Kenyon, at the following address, by regular u.s. Mail, postage prepaid, this 22nd day of August, 2001: Chad M. Kenyon 730 Silveri est Court, Apt. 7 Glenburnie, MD 21061 \)\lCltI"l.~1J' 1+~.0r ~ Debra Hart Munchel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 "--~;""-~!-r:'- C"> -: ., "'"""-~"'_-"'''\-e:,,;,:_,,:__,,?,,,,~"__-;'X~'F.'1':1,'''''''';'",-,~:'-, t-"r'F'!C'--E'~.1-' ',-~' ,o.r_cl~:T:,_1 ".,.;r,o,."",, --'' ,~:--, ~ _'I' ,~~ o-"r:;'.' ^ _"-'_ ""~'_""'__; _ .'"'_,""'~_<'_~,' "" .",'_' !-,., c: c," ,_ ~,-- ,.~, '1 ~ " ,-~- " ~ "~,"'~~~ '--^,.,,--<. ".~r -~,~.,"" 1~""W'r (") c ;f: vcr: iTl~T:' ~~::' ~~: C~; ~8 >c ?---.: -, -< ..~"'mllur'I)" ',.". :'r;~1> ;:.;-) ',-"- ~." ", :''>....) ...-' [:'1 ':J ~~ -< "' i- ~.., r" " ,;>"-," ""_,~, ~'" ~iJl,'!!'_ _f:',.~'~~_~~r~"'~~1J#!l~~I<mffl~-;'t LINNAYA M. KENYON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE CHAD M. KENYON, Defendant : NO. 01-2382 CIVIL TERM CERTIFICATE OF SERVICE I, Debra Hart Munchel, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of the Affidavit of Consent and Waiver of Notice forms signed by the defendant on the defendant, Chad M. Kenyon, at the following address, by regular U.S. Mail, postage prepaid, this 24th day of August, 2001: Chad M. Kenyon 730 Silveri est Court, Apt. 7 Glenburnie, MD 21061 DOO.AC. ~d:~l~~(t Debra Hart Munchel Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 "-l,ltft,, " - - ,.,,~ .- ,<~,- . ~ - " - -, '-T '_," ,,:,>1.>:- -~ --, - -~:-J) -,:~~,,-"~' "--, '-X"':"_'!. ',""" , " LINNAYAM. KENYON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE : NO. 01-2382 CIVIL TERM PRAECIPE TO TRANSMIT RECORD CHAD M. KENYON, Defendant To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 330l(c) of the Divorce Code. 2. Date and manner of service of the complaint: May 3, 2001, by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. 3. Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: by the plaintiff, August 18, 2001; by the defendant, August 20,2001. 4. Related claims pending: None. 5. Date plaintiff's Waiver of Notice in ~330l(c) Divorce was filed with the pronthonotary: August 22,2001. Date defendant's Waiver of Notice in ~330l(c) Divorce was filed with the pronthonotary: August 24,2001. ~O~"~~-k~ Debra Hart unchel ~rtifi~IL /_ T~S M. PLACEt.: ROBERT E. RAINS TERI L. HENNING Supervising Attorneys Date: September 26,2001 F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ,~ .' ,~ t '-'. 1 M - -,~, ., J'",',->,. '. -'-:>'-'I-:_~":;;:"?;<.''1-~~__ --'_._'~," --_:",:i"-"<V_~""'\"":_c ,'--''^''', ";~---",,,,-' -,,~__,~--_,~ ,,- , ,,_,J, 'II" "1 , ~ ~ ~ ",'0' '^' , .~-P""-r------ -',,--'~ 1" ~ ~-- ~,-~ ,. o c ~O..- "'t,lf:-;:"S- 0.1 r~-' ;;>'--- ~-(:' f;J E~, eC) 55;1:;': :;] l/ 1m il1 c:} ':.t') """'/ '-,-, -' '-",' '~;'. C,__; :n t,;:) .. _~~~.~t_ ~___~Jnl,7fm~1J~W.g~i~~~~rf"'~!~~":,,,,\, _ c,,",:,,~.,