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Home My WebLink About01-05986 ~ . . . . . . . ;Ii"':+; '" . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . . . PENNA. STATE OF . . . . . . . . . . . . rynrhiA M~rip rom Pl.::1;nt-iT'T VERSUS . . . Kej tl1 FrlW>'lm C:orn . . . . f)p,fpnn;:mt" . . . . . . . . . . . . AND NOW, . . DECREED THAT . . . . . No. 01 5986 DECREE IN DIVORCE /J~( ct;;:S;;'/"," . ,;)Of)S, IT IS ORDERED AND r,ynthia MariA Corn , PLAINTIFF, AND Keith Edward Corn , 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; . . . . . . . . . . . . . . . . . . . . . . . . . . . "~~\~~'-_'0" ,~" .-0'-", "~~ :"';"__';~_~ , r - ~ , Nfl\lF. T: ATIES/~ PROTHONOTARY . . . . . . . . . Of ;f. :+:'f. 'f. :f:f. 'If' . . . . . . . . . . . . . . . J. . . . . . . . . . .' . " '~'!m~~~;;,ko?;&:t.if.i&.~jjj(f..~illj~;iIt~~it~""~~"","Jl._",-~ !':;-;~'::;::"-'-"~"'~~l!tlliiM~~Il$jt~'" lpL /) riSiJlM' r:::~ /{; .;;:z 'M /(. c2 .os- ,~V~O~" '~-'-~i' . .... tl!.' . . /~";"':' .' ,"" "I' .", : (M'~_~~~ 71~ ,#t~ z7 ~. 1>- % Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY : PENNSYLVANIA CYNTHIA CORN vs. : No. 01-5986 Defendant : CNIL 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: L Ground for divorce: irretrievable breakdown under 9 330l(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. 1930.4(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 9 330l(c) of the Divorce Code: a. Plaintiff: October 30, 2005. b. Defendant: October 30, 2005. 4. J}elated 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. - ."..----.~~ amtiff lOhJw- Date ":>:::"'~-,,"r~ -',-~ ~'"1'" -'Y--_=-_",,-,,~,_ _, '~',>"'" , - ~ 8P ,~ ~'h - .";iV!l~%~jt4,~W1""V4,,,,,,,,"',I>.0,~~JllI1~~il}'l_~l~W1,"~~;~1W"'_"'""N- ,.",-,,,,- '" ~>~,^~,.-,.-~, ~r-' ~=~ ,~~" ". 1'""_'1 ,-.;) :=-.~l w, r~. , , -TJ (.,) c' .~ -". ,""",-.~-,;,,- ,-.",.!-i!;,~liH!!'~"'ii1:';;T"~'-";''0T',~1~;~_'',~~1i\!-1!'~~~ ~~ CYNTHIA CORN, . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLANDCOUNTY, PENNSYLVANIA . (!;uiL'T~ V5. . NO. 01 - S'91'I- . 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 ?i., :.'J!1~f,_,._" ":'>__,,, '-:!i';)',,!,",~-:t_"., t- 1_ "^-~._J;,~ ,,"':"'--- ~-' -f"<, _..' . ~',- ..~ , , wt~ CYNTHIA CORN, . IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . CI~~l~~ V5. . NO. 01 - 59'le. . 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 priDr 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. ",1i~'P_", < "-"'. , f' :~l'J''-'~'~-:''F''-_":,-'" -'''~." '- -,-., , "-_"1 .,- '-~ ,,-"'" ",,-' " ~ 1- N. ~ '- _f[ mr 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. -;' Ji., '"'_ ~,._,_ _ , "'''L, "':""'~"-"'",,';'~",_";':o'-' ,;0,_",__, _ "0 '_I -,.-[ " , , - .' - ~- ' K 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. .FA'1) ~', __,"_T.",~~,__,__.~_"?,_~?.,,,, c'>," -,.' . '0-':;" "'~' .-, "1'- . "I" ,-", " - , t~" '~ 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: &pdL~~ HEATHER L HARBAUGH, ESQ IRE 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 ID #83997 ATTORNEY FOR PLAINTIFF Date: loll Co/ O{ I I ~r",<_,- C'_ ,,"_,~ ":;c'_'",\--'"-'-Y'-~_'~' 7" -",':';" " '''''''''~~l:.--- ,~ ,~ -1 -". - '-"'J ,r. , r;{>'1' """~""~-,~ 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: iD -/(p -0 \ ~ am ~ C a Corn ,R.. -, --';~' -'-<-:. "'''-F~ :,.. . . ''f-'<:'_' ... I ' ~ - -- ".~, -~ " (.) () c::> CJ (\:J "- -'4 c: -"1 lit ..a '- ".. ::::> ~ ...... 0> ...... ""Utii C) h h ~ rn(7': .-1 Z:.Tj ,- Ii) ~ ~~~ '0_ "Q d () ~ .-J ,~ G "- ,'., ""- fJ () 8 d r:: c, '-' )> .-- ~"D =;:-.; \P ~ ~ I zH :-~ ;::.z. i )>c ~ l::f. Xi ![ ? :> ~ f ~ ~, :::> :0 Ul -< r' ~ ._ ,_~ _.c ,'_".~,,",,,",,,, IW' __"'''~''''''',c7 "."""c, ,r;~, __~~"~~~fr!~iH5t$A'tW~~'fi~:l;;:)W?"';i'C"P+!'~*.l-''>:~~~l!iW~~l~~l!L~~tlaT.~~;l'~~.",_ ,;".;i en-- ~b= .. 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 of a Complaint in Divorce, by certified mail, restricted delivery, return receipt requested, to Keith Com, 44 WI 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. Swam to and subscribed before me on this iJ.qf'i\ day of ~{t>'o-P { 200 l. _---f(\~~ C) . ~ ,-) ~lic Notarial Seal Mlf1Iy D. Lehman, Notary Public Harrisburg, Dauphin County My Commission expires Aug. 2, 2004 ,,_ 1 ~,lt. -,-,.,- ~ - "-,1"" - - r, _.< ll'jffl)(,"'rrIIlW'i" U , ^",,-,,,,/,,,~"'l~~ "'-,,,,., , I t II' ~ II :5 c ,0 '.., f '- ,D. .~ :(1) Ul w I .nlis~lD<8i5111e 1118 folloWIng servteeS(ifer an extra leel: 1. 0 .~d!l!Sllee's Add!ess ~.".."'..".,c'." " -' -, -' ",-P"- Consult postmastet for lee. 4a. ArticleNumber. 76(X) 1l.P10 O(X)q Q7'8'SV%2. 4b. SinYice Type D .Rejll~ered El\IlreSll Mall D Insured :':~!l'~ecelpt for Merchandise D COD . Date 01 Delivery Q...)-.l '/ . . fe a's Address (Only if requested oralll1 ~,paid) 1 ""....aftto$llll--.... mile. 'Ia. _'411. '* rint5'oUr.nllmEl and address on the reverse ofthts1Qrm so thai we can retum this card to."you. -Attach this form to the front of the mailpiece. or on the back if space does not permit. -Write-Return Receipt Req~tsd. on the mailpiece below_the artle,le number. -The Return Receipt will show to whom the article was delivere<t anc:tthe'date delivered. 3, Article Addressed to: kvi-ltl &(/1\ LILt LN. SlllL-\-ltI Slt~t CAdl~U ) '?~ (70/~' )i Certified ,- ".,,..-"'" n"i - "'!:'-'~7,"S1',", -" ,_=, _~',O" g i Ul ti. 1 a: c ~. a: Ol c .. :> .2 :> g. ... i, t= . . 011 ,," ."'" .,,'-, '(, y.."'_'nQ_ ,~-':w",;;;, (,- _,~";-~<"""~,~~_~: ~'"" G.1'- ,--";":- -. "',"-',n C>(] 7=>C'\p ::r::~r '" --- ~C>0~ (' "3:\::l-" f' .:s '0 \j.J~ o ~ -mil o C ?: -Om mrn ~~~~~ r:Cs ~ ~ l' ~(j .Pc Z ~ T -'! -~ 'T'~";~"'":rht:\)rii(ni- .,," ;'t"'J.) " 'ffJ,~:!-~",~tj~__"Ll~__i _,::,",:",.n__"_",~"""!fiK_~r.~~~1{;"1jl;!'!i"~\';"'''n'-",,q~,~,,,W~~~~~" ',~_ ~~!,]~<<l_.:,,:+ Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY : PENNSYLVANIA CYNTHIA CORN vs. : No. 01-5986 Defendant : CNIL ACTION : IN DNORCE KEITH CORN 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 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. S4904, relating to unsworn falsification to authorities. ~ ~ ..lfJrn, Plaintiff ~ tol ?{b:) Date j,;'''q,i'W%''0'\W If, ~<~~ ~"~- "'I p~~ , 1'- " ~~,_. " "~r ~ l!iI '-:J ~~~ 1-" ,-- ~,. ~ -, ~.< ~ ..~ ,,~ _fjl.oo:m,~,l~X{(W!,:;'jI,ll\V;";Yi";l,*;lj'~~l{ f' .~,_,~_"'Il'!:m!:!'I'!!~!J_l1~~~!T-'f.""< , ",--- - - ,,,,,,." "X< "'c, W~,"~(l"fii"lr'-J\i!it'{"",'i.fk~ilFi'~Y."-\' 'qiof ~"': '~~ ~~; ~~'< (.I.) "-';', . '-,'-'~">' -,,,~v,v-~n'W~~~it",,,,,_",,,,.,,,,,fl'ifIWWl~~!'!I"H!~~i~ft! C-~ -n .-1 ;:~"1~ '- \C~, C) :~~t(f G) ',..; .), ~~ Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY : PENNSYLVANIA CYNTHIA CORN vs. : No. 01-5986 Defendant : CIVIL ACTION : IN DIVORCE KEITH CORN WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER && 3301(c) & Cd) 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 ifI 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. ~ C amtiff 'on Hall Road Carlisle, P A 17013 e,,,-,_;,~,,,,"""1'lL,,~., _. '". N. ~ , ~ " - lil ~ ~~ "1'''"00''''"'<<"' ""_ n',' - .~ -", "'0' ,,"I '" '<~'--14 ITH~f~";.:5f~;--"i~;i)tt'!i:~~"Yi0t~fJJ~~hf:j:W;:~:YF:?r ~J;IT!~a\il!i!/~1'~~M'f~ _~~,~_~.!'<m'!I!'~~~~M~'llW1~~I:'1'j~k''':R:''ifl'-,"",,":g10T*''''~_'''''~""";'"- ''-,-j' ~~ C) c,n -n '2 -.-; (.-..) ;~'< ("...'; "-' ; ----.~,"n'i!#.~_%(~~~~~'S\f~jJ!;~~,_~, _..... Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY : PENNSYLVANIA CYNTHIA CORN vs. : No. 01-5986 Defendant : CIVIL ACTION : IN DIVORCE KEITH CORN WAIVER OF COUNSELING The undersigned hereby states and certifies as follows: 1. 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. 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. ~4904, relating to unsworn falsification to authorities. (01 ~ 0/ bs-' Date ',- '<i'_"_~-'''''~~,~~>'.:r_w[ ~_..,":""'''''_ "', ['"'co -,~~~~ - , ~ !ill f;,S ~...~~ , ~ , ~l1Zw:-.wr'@I~;'~::r~ ",,~~"_!i"Gn~W\l1J~l"~#0;~;"'~~~~'~~'"1 1ft~~f\~W':,'~"'''':']I'~1""-'.jl;'~'P-''3'_"''< '"-"~,'" -,,-,",'-'+.' """ "'""f.-' '~~I' 'i~Wi':'~"~~li;7'~_-';'-~?~c;;;U-IT,tt'i":~-"'<!:'j~t~~~~;-2: t--::l 1':::3, ~;_;:1 (::J- ","----"', I:,:::' ~'fl C,,: ,-' (.:.) cr, '?"'''''''''''''':f:':;1t''W~~'fi,''lf~'W~'!f!ii!!~; l~d Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY : PENNSYLVANIA CYNTHIA CORN vs. : No. 01-5986 Defendant : CIVIL ACTION : IN DIVORCE KEITH CORN 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 ofthe 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. S4904, relating to unsworn falsification to authorities. ~liV' {/O~ Keith Com, Defendant " 60s ate 1[.. ... ""'~',""",'l'f;\'~l-f!1iIi, '_ , ""-~,., ,- ~" , ! , e, - *_n'.~ ~) ~~ - =~_-.u,~,.,."__~~l~ _~ ,Tr_m~-~w.~'if\~!8t!il.H!ji;\~)';~",W,,*_~!jif""Ai~_"'5t;""'T))T"-"N,';',',>," f~<' .~ u -'1 2~ c..) ~-~-,-; : j ,~,,::: ~"~: :~, (j l>i 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 NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~& 3301(c) & (d) 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 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. ,^ ilea> Keith Corn, Defendant RR 1 Box 272 Dalmatia, P A 17017 IO/l>o/C/s / Dati ~~~~ ',-~'- ,~ ~--'-~ . - ~ '1 -",~~ - .,- . 1 i ,I I I ~ I " I; 'I' .!' -;1 'r: <i,~ ~ [i ~11 " ii " Ii '1:1 _~~~1aLII1W ,-J 0 {:.=-> C::;:;) "';"\ c.n 0 , I C,,) -coo., ~.' C,) ,.,; (J; .<3l~ -. ill. ,.~R"'F1Il'!;';~'Wol''''~$'~~~~~'il-\~'''"'''';''"",,,'''-.,,''n'!.i~,~t~''B'C-'A~"ly-"",,;,~,pc,.;__n;:-_;,');_1;"'''>_''kW;T~~"i').-'!j'iij,,"W['''~;!i~~~ii'?i1:;if,'liH\:~;~]-"f<Ji!lj~;_!''''''_'''!'P",~",Jc:': :'lt1 Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY : PENNSYLVANIA CYNTHIA CORN vs. : No. 01-5986 KEITH CORN Defendant : CIVIL ACTION : IN DIVORCE WAIVER OF COUNSELING The undersigned hereby states and certifies as follows: I. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S4904, relating to unsworn falsification to authorities. tCr\ Keith Com, Defendant o icJb;- at;!'-- .5C_'~,,'f'~\\; ,.~l .. \' _ _. __ , _ ." "" . r , _~ " ." -~"""'" '$'Z'_-~"'~:-__'_"N'~~"'f11rl-'--~"'-''''''''"'""--~ -,--',,",,0', ,","'~ --.~" .___v"'-"'___ ~ '.','~- "......:> ~ ~.,~ C;r'O a {~-:' ~,~.~ , . '-.A_.' ;~j'~'~ t~ ~~ 1 'I j " < , I ;], 1 \1; , , I ! ';;-i .il i, ,I! ii ji i-i ~ ~~ ___~,,___'~_=~___><lM1:lil."'~t;'>ri'f'9",_.","r'~'%fii"mr,W1!~'!!f~iflI1;~_~~!!V,-, '" ~=~~~" .,-"--~- CYNTHIA CORN Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY : PENNSYLVANIA vs. : No. 01-5986 KEITH CORN Defendant : CIVIL ACTION : IN DIVORCE PRAECIPE To the Prothonotary: Please mark counts Three and Four of the above-captioned complaint, pertaining to my economic claims, "withdrawn." Respectfully submitted, Date ''''''.''-'''-'''"'''''C'''-'~^j,_'''l''''''''~!':~ 1-'" TT'...-1n !II (is' (8~ ~'"~ ~p~y~-,."""-,-"",_-."".,,,.-,,-~,." """ -~;C"''''' ~, -<-,~,~-,,,--,. ~& r ~::; /--, c-;:; '::'fi ;;;..n o C) .-,j c..~) :;:::~ c..,) (;.-, ---,-~-,,-~,--.,.~,...-""""'&,,-- - "'Ji["!Ili!:'iilJJJW"!lfM<;f;iI'!"_'!Pi~,*"'b~FP,<'IW_~~i-l'll!M~'i/l;,~.::><}i1N1W'~"";~'lC~"~"".')'f"'""FF'li"- . m --'-,o-;~"";;"O"ffjl'M"~~!Jl!lW'1t~rn,J~~'~.Ji~ $; , ~ 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 6th day of March, 2002 personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Wendy 1. 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 Com, 1236 Newport Road, Duncannon, P A 17020, and the same was received by him as indicated by the return receipt card which is attached hereto. Swom to aI\~ubscribeJil"bt;fore PIe on this _fD..~Aay of ---VllLlJ'U'.L, ~~ O~~~ Notary Public . Notarial Seal MISty p. lehman, NOlalY Pub/' Ham~burg, Dauphin Coun Ie _My Commission EXPires Auq. 2~2004 '0'!\~,;-<",_,_,,,,s~._,!{,._.,_,_, "'__.'-:'T" , ' ,- "_-'1'~' ~"'.-. - ,- r - '--, ~- 1-' ~ -----.. , . , , "" ''1,2,'' _ 4 if Restricted Delivery Is desired. . Pr-irlt your name and address on the reverse $0 that we can retum the card to you. . Att<Ich this card to the back of the maiipiece, or on the front if space permits. x B. Received by (Printed Name) D. Is delivery address different from item 1? D Yes If YES, enter delivery address below: 0 No 1. ArtIele Addressed to: { t~ tt\ (js( t\ .... .~~,'~'1c~d ~~\PA 17~tJ tlnIOC'ff't( q7 rr~'(C40 " . Domestic Return Receipt 1Q2595-e1;.~ 2. Artlcte Number ~_~ms~rvj~J~~eO~~ PS f'o...n 3311 , August 2001 ,", '0,-1--.'- 3. SerVJceType o-d'ertifled Mail 0 Ex)'ress Mail ........ ..-J o Registered Q-f(eturn Receipt ~ o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) as -."'......- ""~ ~,J .,..!t'"~" '" rr ^ ~,~" .- ~" ~, ',., v_~ ~ GJ ~~ t--~ ". ~-N 'f ~ -:r- n ~ ,_. (") c $: ClUJ rpnJ 4L.-- ::1.:) z~; (J) ..: -<<" ~CJ ~o -0 >c: ~ ss BI/ .u'..,.'....< ~ ~ ., ~~~- l< ~~~:1'li'iii_lf!Ji1'!;r~h:.~I~~~~l-:1_fi!*~,'>!"W;At,;;_~'rij?~~\}'\\~~,~J!l~'!ljitl'".~'~~,1J.1?~_~~~i c. to ~~,J\ C '1 ,j ,,*"A- vs Case No. 0(00 ( - OJ~r~ (ote.,J , 1(......'* Statement of Intention to Proceed To the Court: f 't ,J"11.+tA- AA. c.o~ intends to proceed with the above captioned matter. Print NameL1 ~-n(..+ AJ\. ccJRiJ Date: to ( \ v{ 0-5 Sign Name ~ J - Attorney for ~ f' Cl 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 govemed by Rule of Judicial Administration 1901 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 1901." 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) ofthat rule continues to be applicable. II 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 tenninate 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 tenninating 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 tenninated when a party believes that it should not have been tenninated, that party may proceed under Rule230(d) for relief from the order oftennination, An example of such an occurrence might be the tennination of a viable action when the aggrieved party did not receive the notice of intent to tenninate 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 oftennination 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 tenninated An action which has not been tenninated 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 oftennination under Rule 230.2. "'f';'!'mJ'!FJ,:!l..~ ,;.. "..a ,.~ilIi!' ~ ,~~, ~~ 'r-" -~ "~ "._~~i.''''''''.'''' '" = rrrl ,,- =~ IT il, lJftiiJf T~;~!~_.K#I;;::~~~~~&~J~~~)f,til'''}~'''i:''''"'w'V-''' ' ",',,","" '~.'C" _'_, '''"Z_~'' ~~.~. _<'~,,,_ """'~'_V, '~'''.NV'" '11 . " 0 '" 0 ,= C = -n :;:,::- G~'" C) -l . C) ;=11:0 ! -.., , ~ -,..." i' -~~ '''--; N ;f~2 l CI ,', -a ~ ~) c5 \---' $01 C_ -7 ._-, .~ )::--.. -, rr:- :::J '-C 0 .-c ... SUBJECT: Cynthia M. Corn v Keith E. Corn, Pending Divorce 11 October 2005 To Whom It May Concern, I have a pending divorce action here in Cumberland County with Keith Com, I am having trouble contacting my attorney of record, Heather Harbaugh, Esquire regarding said action. Her office has moved and her phone is disconnected. Given the above, I am formally requesting my divorce action NOT be purged and I have more time to try and locate my attorney to clear up the situation. Thank you in advance for your assistance. . om DOMESTIC RELATIONS SECTION Cumberland County . CYNTHIA M. CORN Conference/Enforcemenl Officer . TElEPHONE CARLISLE - 240-6225 WEST SHORE AREA - 697-0371 SHIPPENSBURG AREA - 532-7286 FAX (717) 240-62:48 SCDU '-877-727-7238 13 N. HANOVER ST. P.O. BOX 320 CARLISLE, PA 17013 CyndiCGm@pacses.oom www.childsupport.state.pa.us ,,'"":1-'w~,,'-r!!W,..~ 1, ""~IJf-IIJ.l,~[1l11l~.)ll!I:__l!l _.~A' ~_ :1 - .>-,-'_. ",_c .,' "., -,-,:.,.:,;:'t-',-,-,."'" --'--"',~-- "' ~ ,- ,,~ ~ " ~"" J,!:ri 1If"'f'1i:JAfi~'!W~1f_,,",,",,",,~~l'!~mr"'1'-"tr"'i{'~, ~~, JL, ~~. ,-,-, ,--".., ",,-,,,-< ,,,,'d'>'~" '",'" ft-c t~0l .O_'O",,~c^ '"~,.,~" "ncjfltOT'ic~' . .to 0 "" S = 0 "'~ w~ ." 0 ::;:J M -{ rTlF 1'0 ~E:~ '~~ , ,-. ~-~ v j~~1 -..'" -- '...,.. 2: -,I :::(I .c- 2> _1:1 Cl -< . '''":~,,,.. -'Yl1'Y- -'c-".", ,:<';,/,1;";;,(":_\>' '~'f_r<;.e;_-'~" ~-- -J"yiJ __~~I~IWJ-~Ii~m-Jl-\W'~\I1I!i!P~~J)Ii~~J~$f,