HomeMy WebLinkAbout01-5986
CYNTHIA CORN, . IN THE COURT OF COMMON PLEAS
Plaintiff . CUMBERLANDCOUNTY, PENNSYLVANIA
. C;uiL't~
VS. . NO. DI - S91''-
.
KEITH CORN, . CIVIL ACTION - LAW
Defendant . IN DIVORCE
NOTICE TO DEFEND 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 children.
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 Court House, 1 Court
House Square, Carlisle, Pennsylvania, 17013-3387.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION 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 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 LAWYER REFERRAL SERVICE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
CYNTHIA CORN, . IN THE COURT OF COMMON PLEAS
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
. CI~~L'-r-~
V5. . NO. DI - ~9J'k.
.
KEITH CORN, . CIVIL ACTION - LAW
Defendant . IN DIVORCE
COMPLAINT UNDER ~3301
OF THE DIVORCE CODE
1. Plaintiff is, Cynthia Corn, who currently resides at 230 Union Hall Road,
Carlisle, Cumberland County, Pennsylvania.
2. Defendant is, Keith Corn, whose current residence is thought to be 44 W.
South Street, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania
for a period of more than six (6) months immediately preceding the filing of this Complaint.
4. The Parties were married on January 2, 1998.
5. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
6. There has been no prior action for divorce or annulment instituted by either
of the parties in this or any other jurisdiction.
7. The Plaintiff has been advised that counseling is available and that Plaintiff
may have the right to request that the Court require the parties to participate in counseling.
8. Plaintiff avers that there are no children of the parties under the age of eighteen.
COUNT I.
REQUEST FOR A No-FAULT DIVORCE
UNDER 93301 (c) OF THE DIVORCE CODE
9. The prior paragraphs of this Complaint are incorporated herein by reference
thereto.
10. The marriage of the parties is irretrievably broken.
11. After ninety (90) days have elapsed from the date of the filing of this
Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that
Defendant may also file such an affidavit.
WHEREFORE, if both Parties file affidavits consenting to a divorce after ninety (90)
days have elapsed from the date of the filing of this Complaint, Plaintiff respectfully
requests the Court to enter a Decree of Divorce pursuant to Section 3301 (c) of the Divorce
Code.
COUNT II.
REQUEST FOR A No-FAULT DIVORCE
UNDER 93301(d) OF THE DIVORCE CODE
12. The prior paragraphs of this Complaint are incorporated herein by reference
thereto.
13. The marriage of the Parties is irretrievably broken.
14. The parties are living separate and apart and at the appropriate time, Plaintiff
will submit an affidavit alleging that the Parties have lived separate and apart for at least
two years as specified in Section 3301 (d) of the Divorce Code.
WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce
pursuant to Section 3301 (d) of the Divorce Code.
COUNT III.
REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER 93323, 93501, 93502 and 93503
OF THE DIVORCE CODE
15. The prior paragraphs of this Complaint are incorporated herein by reference
thereto.
16. Plaintiff requests the Court to equitably divide, distribute or assign the martial
property between the parties without regard to marital misconduct in such proportion as the
Court deems just after consideration of all relevant factors.
WHEREFORE, Plaintiff respectfully requests the Court to enter an order of equitable
distribution of marital property pursuant to Sections 3323, 3501, 3502 and 3503 of the
Divorce Code.
COUNT IV.
REQUEST FOR CONTINUED MAINTENANCE AND BENEFICIARY
DESIGNATIONS OF EXISTING POLICIES INSURING
LIFE AND HEALTH OF BOTH PARTIES
UNDER 93502(d) OF THE DIVORCE CODE
17. The prior paragraphs of this Complaint are incorporated herein by reference
thereto.
18. During the course of the marriage, Defendant has maintained certain health,
life and death insurance policies for the benefit of Plaintiff and Defendant.
19. Pursuant to Section 3502(d), Plaintiff requests Defendant be directed to
continue maintenance of said policies.
WHEREFORE, Plaintiff respectfully requests that, pursuant to Section 3502(d) of
the Divorce Code, the Court enter an order directing Defendant to continue to maintain
certain life and health insurance policies for the benefit of Plaintiff and Defendant.
Respectfully submitted:
BY: C4~~~~
HEATHER L. HARBAUGH, ESQ IRE
2650 North Third Street
Harrisburg, PA 17110
(717) 238-2200
10 #83997
ATTORNEY FOR PLAINTIFF
Date: lol/f.D/O(
I I
VERIFICATION
I, Cynthia Corn, hereby swear and affirm that the facts contained in the
foregoing Complaint for Divorce are true and correct and are made subject to the penalties
of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Date: {D -jl.R -0 l
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LAW OFFICE
EDWARD J. WEINTRAUB
2650 NORTH TJ."'lD STREET
HARRISBURG, PENNSYLVANIA 17110
(7171238-2200 FAX (717) 238-9280
CYNTHIA CORN, * IN THE COURT OF COMMON PLEAS
Plaintiff * CUMBERLANDCOUNTY, PENNSYLVANIA
*
vs. * NO. 01-5986 Civil Term
*
KEITH CORN, * CIVIL ACTION - LAW
Defendant * IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
: ss.
COUNTY OF DAUPHIN
AND NOW, this 29th day of October, 2001 personally appeared before me, a Notary Public in and
for the aforesaid Commonwealth and County, Wendy L. Shive, who being duly sworn according
to law, deposes and says that on October 24,2001, she mailed a certified copy ofa Complaint in
Divorce, by certified mail, restricted delivery, return receipt requested, to Keith Corn, 44 W / Spitj
Street, Carlisle, PA 17013, and the same was received by him on October 26, 2001 as indicated by
the return receipt card which is attached hereto.
Sworn to and subscribed before Ie
on this :}..q~ day of ('r~'o.f
2 GO 1.
_~-tM()'~k)
Nota; Public
Notarial Seal
M~ D. Lehman, Notary Public
Hliirisburg, Dauphin County
My Commission ExpIres Aug. 2, 2004
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CYNTHIA CORN, * IN THE COURT OF COMMON PLEAS
Plaintiff * CUMBERLANDCOUNTY, PENNSYLVANIA
*
VS. * NO. 01-5986 Civil Term
*
KEITH CORN, * CIVIL ACTION - LAW
Defendant * IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYL VANIA
: ss.
COUNTY OF DAUPHIN
AND NOW, this 6th day of March, 2002 personally appeared before me, a Notary Public in and for
the aforesaid Commonwealth and County, Wendy L. Shive, who being duly sworn according to law,
deposes and says that on March 4, 2002, she mailed a certified copy of a Complaint in Custody and
Petition for Emergency Injunctive Relief, by certified mail, restricted delivery, return receipt
requested, to Keith Corn, 1236 Newport Road, Duncannon, PA 17020, and the same was received
by him as indicated by the return receipt card which is attached hereto.
Sworn to a~ubscribeR,.b~ore Ple
on this -lD-~ Aay of ---lULlJ'Ul-,
2002.
Notary Public
M' Notarial Seal
JZrgj, lehman, Notary Public
My C urg, Dauphin County
_ ommlsslon EXPires Auq. 2. 2004
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Plaintiff
*
*
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CYNTHIA CORN,
*
vs.
* NO. 01-5986 Civil Term
*
KEITH CORN and ELORIA ROMO,
Defendants
* CIVIL ACTION - LAW
* IN DIVORCE
PETITION FOR CONTEMPT AND
EMERGENCY INJUNCTIVE RELIEF
COMES NOW, Cynthia Com, Plaintiff, by and through her attorney Edward 1. Weintraub,
Esquire, and makes this petition as follows:
1. PetitionerlPlaintiff is Cynthia Com who currently resides at 230 Union Hall Road,
Carlisle, Cwnberland County, Pennsylvania.
2. Respondents/Defendants are Keith Com and Eloria Romo, who are currently believed
to reside together at 1236 Newport Road, Duncannon, Perry County, Pennsylvania.
3. This Court's Order, dated May 30, 2002, orders the parties in this matter to contact
Dr. Stanley Schneider and schedule an initial session for a custody evaluation within ten (10) days
of the date of the Order. A true and correct copy is attached hereto as Exhibit "A."
4. Although Petitioner has paid Dr. Schneider and has had her initial evaluation
appointment, neither Respondent has yet paid or seen Dr. Schneider. Respondent Keith Com has
canceled appointments on two occasions and Respondent Eloria Romo has never contacted Dr.
Schneider's office to schedule an appointment.
5. Petitioner believes and therefore avers that the Respondents have, or are planning
to, enroll the minor child, Coda Z. Romo, in the Perry County School District for the upcoming
2002-2003 school year commencing in August, 2002.
6. The minor child is has been enrolled in the Bellaire Elementary School in the Carlisle
School District where he has lived with Petitioner since December, 1997 and is scheduled to begin
the Second Grade in August, 2002.
7. The teachers, administration and special educators are aware of Coda's special needs
and have implemented an instructional support plan to assist Coda in his education utilizing a
reading support instructor, meetings with a guidance counselor and a reading plan for this summer's
vacation.
8. Due to the Respondents failure to schedule with Dr. Schneider in a timely manner,
the custody evaluation has been delayed, thereby delaying any trial of this matter until well after the
school resumes.
9.
School.
It is in the best interests of the child to continue as a student at Bellaire Elementary
WHEREFORE, PetitionerlPlaintitI respectfully requests this Honorable Court to find the
Respondents/Defendants in willful contempt of the May 30, 2002 Order for their failure to proceed
with Dr. Schneider's custody evaluation in a timely manner and enter an Order directing the
Respondents to do so within ten (10) days AND enter a Further Order prohibiting the Respondents
from enrolling the minor child in the Perry County School District, or at any school other than
Bellaire Elementary School, pending further proceeding in this matter. AND be it further Ordered
that during the 2002-2003 school year, or until further Order of the Court, the minor child shall
reside primarily with Petitioner in the Carlisle School District and Respondents shall have partial
physical custody on alternating weekends from Friday at 7:00 p.m. until Sunday evening at 7:00
p.m. and and upon 48 hours notice to Plaintiff, one mid-week visit in Cumberland County should
either Respondent elect to travel to Cumberland County for a mid-week visit.
Respectfully submitted:
Dated: I! '1-(~ 'z../
J. WE
2650 N. Third Street
Harrisburg, P A 17110
ID # 17441
(717) 238-2200
Attorney for Plaintiff
07/01/2002 12:48
71 72389280
STERN OR WEINTRAUB
PAGE 05
VERIFICATION
I, Cynthia M. Com, heJ'eby swear and affinn that the fuets contained in the foregoing
Petition for Contempt and Emergency Injunctive Relief are true and correct and are made subject
to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities.
Date:-e. c.J\ ,
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MAY 2 9 2002~
CYNTHIA M. CORN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-992
CNIL ACTION LAW
KEITH E. CORN and ELORIA A. ROMO,
Defendants
IN CUSTODY
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ORDER OF COURT
AND NOW, this 3o-::flv day of '"n1 ~ ' 2002,
upon consideration of the attached Custody Conciliation Report, it is oraered and directed as follows:
1. The prior Orders of this Court dated February 18, 1998 and September 16, 1999 are vacated
and replaced with this Order.
2. The parties shall submit themselves, the Child, and any other individuals deemed necessary
by the evaluator to a custody evaluation to be performed by Stanley Schneider, PhD. or other
professional selected by agreement of the parties and counsel. The purpose of the evaluation shall be
to obtain independent professional recommendations concerning ongoing custody arrangements which
will best seIVe the interests of the Child. The parties shall sign all authorizations deemed necessary by
the evaluator to obtain additional information pertaining to the parties or the Child. All costs of the
evaluation shall be shared equally between the parties. All parties shall contact the evaluator within 10
days of the date of this Order to schedule his or her initial session.
3. On a temporary basis, pending completion of the custody evaluation and further Order of
Court or agreement of the parties, the Mother, Eloria A. Romo, the Father, Keith E. Corn, and the
Step-mother, Cynthia M. Corn, shalI have shared legal and physical custody of Coda Z. Romo, born
October 30, 1993, as follows:
A. The parties shall have an equal right, to be exercised jointly with the other parties, to
make all major non-emergency decisioJls affecting the Child's general welI-being including,
but not limited to, all decisions regarding his health, education and religion. Each party shall
be entitled to all records and information pertaining to the Child including, but not limited to,
school and medical records and information. Each party shall notifY the other parties as soon
as possible in the event of a medical or other emergency concerning the Child. All parties shall
be equally entitled to contact school personnel and participate in school activities as
appropriate.
,
B. During the remainder of the 2001-2002 school year, the Mother shall have custody
of the Child from Friday, May 24 at 7:00 p.m. through Sunday, May 26 at 7:00 p.m., the Step-
mother shall have custody of the Child from Sunday, May 26 at 7:00 p.m. through Friday, May
31 at 7:00 p.m., the Father shall have custody from Friday, May 31 at 7:00 p.m. through
Sunday, June 2 at 7:00 p.m., and the Step-mother shall have custody from Sunday, June 2 at
7:00 p.m. through Friday, June 7 at 7:00 p.m.
C. After termination of the school year in 2002, beginning on June 7 at 7:00 p.m. the
parties shall share having custody of the Child on a rotating weekly basis beginning with the
Mother having custody for the first week. The Mother shall transfer custody to the Father at
the end of her weeks, the Father shall transfer custody of the Child to the Step-mother at the
end of his weeks and the Step-mother shall transfer custody to the Mother at the end of her
weeks. The rotating 3 week cycle shall continue on an ongoing basis with the exchange to take
place every Friday at 7:00 p.m. pending completion of the custody evaluation and further
Order of Court or agreement of the parties.
4. Exchanges of custody between the Step-mother and the other parties shall take place at the
North Middletown Police Department unless otherwise agreed.
5. The custodial party shall cooperate In ensunng that the non-custodial parties have
reasonable telephone access to the Child.
6. The Step-mother shall be responsible to provide copies of the Child's insurance information
to the other parties as well as the prescribed medications for the Child with instructions for
administration.
7. None of the parties shall drive with the Child in a motor vehicle without a current driver's
license.
8. None of the parties shall do or say ~ything which may estrange the Child from any other
party, injure the opinion of the Child as to any other party, or hamper the free and natural development
of the Child's love and respect for any other party. All parties shall ensure that anyone having contact
with the Child complies with this provision.
. -._,...._._._...,.._..~~----..........."_.,..-
9. Within 60 days of receipt of the evaluator's written custody recommendations, counsel for
any party may contact the Conciliator to schedule an additional Custody Conciliation Conference in
the event that all custody issues have not been resolved by agreement.
BY THE COURT,
/S/ ~'>lL ~
Kevin A. Hess, J.
cc: Heather L. Harbaugh, Esquire - Counsel for Plaintiff7Step-Mother
Nathan C. Wolf, Esquire - Counsel for Father
Karl E. Rominger, Esquire - Counsel for Mother
,
TRUE COpy FROM RECORD
In Testimony whereof, I here unto set myhancl
'nd the sea/ of said Court at Carlisle, Pa.
Thl. ....~(.~.. day Gf......7.L?~..~ ..r?h~..2..
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CYNTHIA M. CORN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
02-992
CIVIL ACTION LAW
KEITH E. CORN and ELORlA A. ROMO,
Defendants
IN CUSTODY
PRIOR JUDGE: Kevin A Hess
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Concili~tor submits the following report:
I. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
Coda Z. Romo
October 30, 1993
CIlRRENTLY IN CUSTODY OF
Father
2. A Conciliation Conference was held on May 23, 2002, with the following individuals in
attendance: The Plaintiff/Step-Mother, Cynthia M. Com, with her counsel, Heather R. Harbaugh,
Esquire, the Father, Keith E. Com, with his counsel, Nathan C. Wolf, Esquire and the Mother, Eloria
A. Romo, with her counsel, Karl E. Rominger, Esquire.
3. The parties acknowledged the overriding importance to the Child of reducing stress and
conflict in the custody situation. They agreed to participate in a custody evaluation to obtain
information concerning the Child's needs and interests in an effort to reach a resolution without
increasing conflict. .
4. The Mother expressly reserves the right to take any action available to her by law to pursue
her challenge to the Plaintiff's standing in this matter.
5. The Conciliator submits an Order in tlie form as attached reflecting the parties' agreement to
obtain a custody evaluation. The temporary custody arrangements are the recommendations of the
Conciliator.
Date~
CJ- 8-/ d'Oc>a-
,
CL.JA ~
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Dawn S. Sunday, Esquire
Custody Conciliator
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Statement ofIntention to Proceed
To the Court:
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intends to proceed with the above captioned matter.
Date:~
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Print NameL't ~-n{...1\- AA. (CJhJ
Explanatory Comment
The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit
comment.
I. Rule of civil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously
governed by Rule of Judicial Administration 190 I and local rules promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d
1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required
before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 190 I."
Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable.
11 inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties.
If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of
course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she
will file a notice of intention to proceed and the action shall continue.
a. Where the action has been terminated
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Rule230( d) for relief from the order of termination. An example of such an occurrence might be the termination
of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file
the notice of intention to proceed.
The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of
the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff
must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of
termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2).
B. Where the action has not been terminated
An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may
have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a
common law non pros which exits independently of termination under Rule 230.2.
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SUBJECT: Cynthia M. Corn v Keith E. Corn, Pending Divorce
II October 2005
To Whom It May Concern,
I have a pending divorce action here in Cumberland County with Keith Corn,
I am having trouble contacting my attorney of record, Heather Harbaugh, Esquire
regarding said action. Her office has moved and her phone is disconnected.
Given the above, I am formally requesting my divorce action NOT be purged and I have
more time to try and locate my attorney to clear up the situation.
Thank you in advance for your assistance.
- -----~-
. orn
DOMESTIC RELATIONS SECTION
Cumberland County
.
CYNTHIA M. CORN
Conference/Enforcement Officer
TElEPHONE CARLISLE - 240-6225
WEST SHORE AREA - 697-0371
SHIPPENSBURG AREA - 532-7286
FAX (717) 240-6248
SCDU '-8n.727-7238
13 N. HANOVER ST
P.O. BOX 320
CARllSlE. PA 17013
CyndiCom@pacses_com
www.chik:lsupport.stat8_pa.us
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CYNTHIA CORN
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
vs.
: No. 01-5986
KEITH CORN
Defendant
: CIVIL ACTION
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 17, 2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of the filing and service of the complaint.
3. I consent to the entry of a final Decree of Divorce after service of notice of intention
~
10/ )D
Date
b)-
to request entry of the Decree.
I verify that the statements made in this waiver 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.
--~"
1a Corn, Plaintiff
CYNTHIA CORN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
Plaintiff
vs.
: No. 01-5986
KEITH CORN
: CIVIL ACTION
: IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER ~~ 330J(c) & Cd) OF THE DIVORCE CODE
I. 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! do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a Decree of Divorce 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 waiver are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn
falsification to authorities.
-
Ct', amtiff
30 Union Hall Road
Carlisle, P A 17013
CYNTHIA CORN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
Plaintiff
vs.
: No. 01-5986
KEITH CORN
: CIVIL ACTION
: IN DIVORCE
Defendant
WAIVER OF COUNSELING
The undersigned hereby states and certifies as follows:
I. I have been advised of the availability of marriage counseling and understand that 1
may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors, which list is
available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
94904, relating to unsworn falsification to authorities.
-
)
lo/?ok>
Date
mtiff
€
CYNTHIA CORN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
Plaintiff
vs.
: No. 01-5986
KEITH CORN
: CIVIL ACTION
: IN DIVORCE
Defendant
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 17, 2001.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of the 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 waiver are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn
falsification to authorities.
/)/' f "
,.:/ ;/ (
/ "; / 1 .
//t,'Lt ,I C "-
Keith Corn, Defendant
1/ .- 0"
Ir) jO n<
.bate .'
,~
-~~..""..
CYNTHIA CORN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
Plaintiff
vs.
: No. 01-5986
KEITH CORN
: CIVIL ACTION
: IN DIVORCE
Defendant
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE
UNDER 99 3301(c) & (d) OF THE DIVORCE CODE
I. I consent to the entry of a final Decree of Divorce without notice.
2. 1 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 Decree of Divorce 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 waiver 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.
)
r
v/ ',' _--L
,~U..
VI ~
Keith Corn, Defendant
RR I Box 272
Dalmatia, P A 17017
( c:.-\
"Y'7 A
( I -,>:1 C)5
/ Dati .
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
CYNTHIA CORN
vs.
: No. 01-5986
KEITH CORN
Defendant
: CIVIL ACTION
: IN DIVORCE
WAIVER OF COUNSELING
The undersigned hereby states and certifies as follows:
I. I have been advised of the availability of marriage counseling and understand that I
may request that the Court require that my spouse and I participate in counseling.
~i
, ,
/"1 /,/
IIA: ,> C (",,\
Keith Corn, Defendant
/' . ,,' .) i "
. ( .'/ :~i I{:>':,
bat;( -
2. I understand that the Court maintains a list of marriage counselors, which list is
available to me upon request.
3. Being so advised, I do not request that the Court require that my spouse and 1
participate in counseling prior to a divorce decree being handed down by the Court.
I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.
~4904, relating to unsworn falsification to authorities.
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
CYNTHIA CORN
vs.
: No. 01-5986
Defendant
: CIVIL ACTION
: IN DIVORCE
KEITH CORN
PRAECIPE
To the Prothonotary:
Please mark counts Three and Four of the above-captioned complaint, pertaining to my
economic claims, "withdrawn."
Respectfully submitted,
la Co , Plaintiff
Date
~
-- )
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY
: PENNSYLVANIA
CYNTHIA CORN
vs.
: No. 01-5986
Defendant
: CIVIL ACTION
: IN DIVORCE
KEITH CORN
PRAECIPE TO TRANSMIT THE RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
I. Ground for divorce: irretrievable breakdown under S 3301 (c) of the Divorce Code.
2. Date and manner of service of the complaint: October 26,2001, by regular and
certified mail, restricted delivery, return receipt, pursuant to Pa.R.C.P. I 930.4(c). The Postal
Service return receipt, PS Form 3811, was filed of record herein.
3. Dates of execution of the Affidavit of Consent to Entry of Divorce Decree required
by S 3301(c) of the Divorce Code:
a. Plaintiff: October 30, 2005.
b. Defendant: October 30, 2005.
4. Related claims pending: None. On October 31, 2005, the Plaintiff filed of record
herein her Praecipe withdrawing her economic claims.
5. Dates of filing Waivers of Notice with the Prothonotary:
a. Plaintiff: October 31, 2005.
b. Defendant: October 31,2005.
~
(C) h J 6-t-
... CynthIa
amtiff
Date
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IN THE COURT OF COMMON
STATE OF
rynthin Mnrip rorn
Pl~int-if"f"
VERSUS
Ke.ith FilWnrr1 rorn
~fpnr1;:mt-
AND NOW,
DECREED THAT
,
AND
Keith Edward Corn
OFCUMBERLANDCOUNTY
PENNA.
No.
01 5986
DECREE IN
DIVORCE
PLEAS
~~(
ctJ:SrJ-tM .
, ;)oOS. IT IS ORDERED AND
Cynthin Mnrjp- Corn
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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~.++'+''+'''''++++++'+'++++++'+',.;~
, PLAINTIFF,
, DEFENDANT,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
YET BEEN ENTERED;
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
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PROTHONOTARY
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