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Home My WebLink About01-07072 ".y!>~~ . . . . . . IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND COUNTY . . PENNA. STATE OF . . . . . . MICHAEL D. BLESSING, . No. 7072 ?nn1 Plaintiff . . . . . VERSUS ('VN'l'HTII T. RT.R~~T1\TC:, . Defendant . . DECREE IN DIVORCE . . . . . . . . . 1'9....... 'I 10 , ~o 2-, IT IS ORDERED AND AND NOW, DECREED THAT Micha~l 0_ Rl~RRing , PLAINTIFF, . AND Cynthia L. Blessinq , 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. . :Ii'" "':Ii "':Ii . . . . . . . . /J 2td4'(~ PROTHONOTARY . . . .. . . . . . . >, ~, .,~~ ~ " '1'" -,"',- " ,.-- -,. ~r '! "-< .-,,',<,-...... ,-, .f . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . r" ,~ !iI t '7Y~ ~Z~~ ~ ~ p7-~~.pv o ,~. UIIII WHn~-".TJf" r:v, II It- ?"'f? '~Ir ,. ,'"~>.~_ = ."=:~~~ !>,~,~,Il~<~~~~~~." _ -'" '.-"'_""'~~'~~"'''''~''''_.",~~~~~'l'~3j',~r,sili1'5''2-~~:,~-;'l.;;;'~~~~~~~W'!ft1!i~-ffi~~lllli."~t;': v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY MICHAEL D. BLESSING, Plaintiff CYNTHIA L. BLESSING, Defendant : NO, 01-7072 CIVIL TERM PRAECIPE TO TRANSMIT RECORD 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: December 17,2001, 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, April3, 2002 ; by the defendant, April3, 2002. 4. Related claims pending: none. 5, Date plaintiff's Waiver of Notice in g330l(c) Divorce was filed with the pronthonotary: April 3, 2002. Date defendant's Waiver of Notice in g3301(c) Divorce was filed with the ~M~Uu-- ~ Lily . Cheung C". ified Legal Intern .--.~ THO ROBE E. RAINS Supervising Attorney LUCY JOHNSTON-WALSH F AMIL Y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 717/243-2968 pronthonotary: April 3, 2002. Date: April 4, 2002 '; -'~i"",,~ _ ,''-,,_',,__,;!,-__,,''';<:'_; -",',~"'f',~<-;,r-W"~h"""A",--..f", ~ ,,,~',"i"~_ '"!'__~~~"__""',,,!, """,,. '~"" ,,,"-,c:',,, _'/"-'-'[- ~:;~ ,'",. ~,__, __ ""," -"""_'-".:-'_'"':"""",,,,,~-_-,,; c,""""'~- '__,'_;<_'''^'',_,"..'', ;_'_~__,",_." !l'!, __--'-ll " .'.--'" - --, :-~ ~ ! ~""1 ,~"", . "J.f:!~ _~" <,'_ ",,'_o,~_ ~'". """,,"," .,. ,. b fE ""Om CP"J ",-:t. Zr' Cf) ;? -<,.-., ~6 ~o )>:0 c: ~ , "'-lIITJf o N ".. " A1 t ~' o ->1 .-, "Y" :'f1;-!,.l :i3fg (), ! :39 ,};- -T' _.)-~ Zl."} om ~ -< "'"', :z '!? N (Xl -~":,<, __,~, -~ ~~~-''-''_~'~If'<,,:,~~,~~>\~:\~~~'iftf$~~~~IIi1!l~il!l~~,l$ MICHAEL D. BLESSING PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. 01-7072 CIVIL ACTION LAW CYNTHIA L. BLESSING DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, December 20, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective cOlillsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberlaud County Conrthouse, Carlisle on Thursday, Jauuary 10, 2002 at 10:30 AM for a Pre-Hearing Custody Conference, At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR 1HE COURT, By: Isl Hubert X. Gilroy. Esq. ~ Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE TillS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HA VB AN ATIORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FOR1H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 ""-''''''''!';;:#\I>Ijl~ _,,; ,_ ,~, '/"'l""_ . ", ", - ~ , ~< , , ._ '~t=''''r~ Iii -.. ' . '....,.,~ .H.."li,llilll[ITrj4gV".(1i~' 1(1 Sf^077):1J Arftl 0; I )?3?~d AdOfJ -ftJ3([ Of' )37 '."\)\.U -;n,lfO(Y ~(j r W Of )~_J~1.V J-cJ{), r'3D -IQj''eIr:/ JJN~(~~!\~~~~V1n8 oZ:l\;1d \2'))1)\0 ",; .:i~,J,'l .,\0 \ i""': '\;(J"\(l', ",J" ' - ~\j"i1.0\\\J1 'i- .Y'J:nH . , ;;{\\\-\:k..,t\,...J' ..J"-"'w 714 . vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01- ':J01~ CivilTerrn MICHAEL D. BLESSING, Plaintiff CYNTHIA L. BLESSING, Defendant ACTION IN DIVORCE ORDER OF COURT AND NOW, this day of ,2001, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , Esquire, the conciliator, at , Pennsylvania, on , the day of ,2001, at o'clock .m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either party may bring the child who is the subject of this custody action to the conference, but the child's attendance is not mandatory, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By Custody Conciliator 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. OFFICE OF THE COURT ADMINISTATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR CARLISLE, PA. 17013 (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accomodations 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. O'('i,lW,4:]I!!,'$',?m__l~"__,,..,_ t ,'"I ~ '"0 ,~_~4 ~", ",.,.....,. ~~ _ J ~,' ~"~_,, ,~__ c -~ , "" ~ =m"~",,""~~"" , ~''ll!ill'l''ll\"~~"~ vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No.O lv'1D'1~ Civil Term : ACTION IN DIVORCE MICHAEL D. BLESSING, Plaintiff CYNTHIA L. BLESSING, Defendant 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 Bar Association 2 Liberty A venue Carlisle, Pa. 17013 (717) 249-3166 , ~1'-,".F,t"i:I,c " __ .J'~_" _'>_"~~ ~'~ -]iI!l~ ~ , t " "~ IIl_ "~ -r"'~ MICHAEL D. BLESSING, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No.6}- 767 d- Civil Term : ACTION IN DIVORCE CYNTHIA L. BLESSING, Defendant COMPLAINT COUNT I - DIVORCE 1. Plaintiff is Michael D. Blessing, a competent adult individual, who has resided at 13 S. Hanover St., Carlisle, Cumberland County, Pennsylvania, since August 2001. 2. Defendant is Cynthia L. Blessing, a competent adult individual, who resides at 329 N. Hanover St., Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing ofthis Complaint. 4. The Plaintiff and the Defendant were married on July 18,1981 in LewistoWll, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7, Plaintiff and Defendant have two children together, namely, Noah M. Blessing, d.o.b. 1/31/91, and Harley D. Blessing, d.o.b. 7/15/93. 8. Plaintiff and Defendant are both citizens ofthe United States of America, 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies, ',~~~"#1F.o'i~, n~ _ ~ ,.,_~ U,jj!,..,~ """~'_.~' " "L"T" "~_ ,-~,""'- . . 7'~ ., ~,~ -""" __ ~"~_ -,~<. .~._- 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. COUNT II - CUSTODY 11. Plaintiff is Michael D. Blessing, who currently resides at 13 S, Hanover St., Carlisle, Cumberland County, Pennsylvania. 12. Defendant is Cynthia L. Blessing, who currently resides at 329 N, Hanover St., Carlisle, Cumberland County, Pennsylvania. 13. Plaintiff seeks partial custody of the following children: NAME ADDRESS DOB Noah M. Blessing 329 N. Hanover St., Carlisle, Pa. 17013 1/31/91 Harley D. Blessing 329 N. Hanover St., Carlisle, Pa. 17013 7/15/93 The children were not born out of wedlock. The children are in the custody of: Mother, Cynthia L. Blessing. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Cynthia L. Blessing 329 N. Hanover St. 8/1/01 to present. Carlisle, Pa. 17013 Cynthia L. Blessing and Indian Springs Trailer Park 2/99 to 8/1/01 Michael D. Blessing Shippensburg, Pa. Cynthia L. Blessing and 425 N. Hanover St. Birth to 2/99 Michael D. Blessing Carlisle, Pa. 17013 '_ij,4"11>W"~",,". '!'" ,....".."p<,~.,.,""""" ~,",,'_._ f~.~~1l'..., .~~ , ' I' , .~ '",' , ~~ ~~.- ~-;-. , ~ I' The mother of the children is: Cynthia L. Blessing who is currently residing at: 329 N. Hanover St., Carlisle, Pa. 17013, She is married. The father of the children is: Michael D. Blessing currently residing at: 13 S, Hanover St., Carlisle, Pa. 17013. He is married, 14. The relationship of plaintiff to the children is that of FATHER. The plaintiff currently resides alone. 15. The relationship of defendant to the children is that of MOTHER. The persons that the defendant currently resides with are: the children. 16. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Plaintiff does not know of a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 17. The best interest and permanent welfare of the children will be served by granting the relief requested because: it would be in the children's best interest to enioy regular and cominuin& quality contact and visitation with their father. 18. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. --7"";'J"'1'-<_'"~~~"~_",,~_,,,~,, 0" T8"f", " ~~~. , ^ '""'"'~"~ ~ " ~~ .--, -- ,,' &-:i . . . , WHEREFORE, Plaintiff requests the court to grant partial custody of the children. I verify that the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa,C,S, ~4904 relating to unsworn falsification to authorities. ~~ Michael D. Blessing, Plain Date: Ie?? 1/7-DI ane A ams, squire LD. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF " " , I , -j i ", .. .. t!".,,,;~F-'lf~,':i,,.~,"~'. .~l{""__ '~," j, - -",,',- . 1'_ ~ - ~~~.., :~ ,. - t~. l' ~,_ I @ ~ t ~ - -... ~ "" ~ 00 .J..! -..() !;"'~""",....... gI """'" );l... ""D +-- ~- }\.) <. 0 ~YI & d i:~ '>:l... Ii<. ~'l2 ';;. ,,<-1- J ~ '" o '. " $: ~ ..~ e~ _~, "0 *,-..,g..",,,,,,,,,,, Tirililrilllflr'f!lmi'~'F"X " . ~ ~ ~ -, ::-) YJ ~~] i ~ """- ") () -y 0 0 r>') -, ......" 0- C':~,: (:- ~ : . "::i "." \J ?~;;:) 'X. ,.;,.> ;~,' j ';:---- :u - .j ~ -< ~ ~ . '!!J'q'! 11": it ,~~"",.m"J.,1~ .'~ "', ~~~~~~,~~.p.~'~''i,;q!!i?0''~iW,jCiri~.~~("',i'';-:;'' -,';'j1':n~:"'!,~::'''' ~&".,\,,~;';;:-'\f"~~;\lIi'!ftj'-5.?~j'i~"'l[!'-"';'W"J""':~~~~]~~WJfi1!J}~ MICHAEL D. BLESSING, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 7072 Civil Term 2001 CYNTHIA L. BLESSING, Defendant ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on O?aevv.hev- j-~ a.6ol. 2. The marriage of 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 affidavit are true and correct. I also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: L/' I ' 02- WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER Ci3301(cl OF THE DIVORCE CODE 1. I consent to 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. !i4904 relating to unsworn falsification to authorities. Date: 4;. ()2- Michael D. Blessing, Plainti -;"i,'~I1:,,,,,r~ '... ~oO ,,_, '..~ ."" ,~, " ,< I~ - _~ l!I " <_, "'_. ',<," ~ __ "_" v'" '^_, ~~~:~ "'_"'<~~'1"",m-1il!~..4,",~,-~,~~",. .~..- ',".,~ '~-""", ,,' ;~.."- ., "",.."". i-"'<Zl.d'rniillii"h""'~"''"'~1;:lfTI1Cit'''''~ti;-Jfrf't1f1'?i'~ 8 $:' -ern 52fZ! :CJ~':' (I), )., rS: ;Z' ~o ~C) j3:0 ~ ~ o l'V 'J:>>o .., ~ , <:..3 "'"0 :J1: '::? - ~ i! rq:J) r- ~"9m ..ot:) () j .,..~;C') :r:.''fj n::n ~D urn ~ -< 0'1 :i I ! I I '! I I I I I I I I , , " I , _",'jJ.;~>;Yi~~'-'!'~': )~";"'tW''''':~"*'-'ffi:h~~.m~~~~~;,,1 ~ .i!Q!!lfi.."1 v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY MICHAEL D. BLESSING, Plaintiff CYNTIllA L. BLESSING, Defendant ,: NO. 01-7072 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301(c) of the Divorce Code was filed on December 17, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a fmal decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date t.j -3 - () d-- ~~d6~ Cyn 'a . Blessing, Defend -:),^" ,,"',0"'''-,' c. .;, ."<J ',^'<;"'-~> '4~-':~F,,',':'l"^7"--,~' ..L.,:':_'-", ;.".,' ,K_",'.,.-_" ~'''"",1~'''''''r' ',."":,,,.,"'';i''~' ," .'. , .,,<__, ,''''-- " ",;,.~",~,"""""",,,A " ,__,..__c r' ~, ,_ '." ."" ~ - , --,~, '~.' ,~" , -- '" liI '", .,,__^~,:. ",>F .,.'.. ,"(- ~,"","",~''''1'-,;:<::~,:." r;:,.~,,,."~.;;,,,' ',~,~ -,"'-',:C' '-=,"'.~ ' "~" 'C'''''''_ ~,"'.'., .'-, ""~"lil""lt~I!Y~~F1',~::""';''';' - "'''''''-''l;,''''^~'.ill''''~''''''''''Jk'"'m1mr._ _. _" "~'''')''"'''--$- C) c: s: :t.1frj 111;-r:.- -'-..; 2:-t, 1~2;%i .,.-' , ?i(; """0 :Be: :;? ~ '-'''''~~,~''''~~.' ":"',~,'~". '.-"-- "'I',1?"''L~\'1\" "!~_'"~"'. ~.'5 R5 l:l. '0 ::0 I C.d o -17 ~: -.it - - ::::/ ;:,~i;g .''':'Jj-t( L~~f (j'tJl j;:: ..0 """ ~"'> (.1'1 '_ ~~':'f!'~'<;"'-r;"'~=:' ~~\H cl'".....,.. v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY MICHAEL D. BLESSING, Plaintiff CYNTHIA L. BLESSING, Defendant : NO, 01-7072 CIVIL TERM W AlYER 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 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 1 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: '!-3-dJ "'~tf; '.;", -,'cc;-_- -,.,., ~ ~-'~'-'~"~' "-<, <. 'i~,".",.;,,;r;:.-::,";,'i" '" ,,- '"C"~,',,,, , ,":~ ~~ . - 0 ""~-,.-,(~,.1[,- " '~",~..-';>i,'''''',".:,~,,"~, ,c'; -- "~ - "' ..~ "",>>""",","",,~,",~,<,,".,-,,",,- '""_0,";' ""~'=""'!n!l!ll'il!"r"fililltiiil'jl\fi'))'~"'1i), (") 0 0 c "'> " ~. ". "TJi;'i! V C-'''''''':.' mlr' >;0 Z':t, -'-',rn ZC t...., ~'-~ 9 Cf) .,,:~ ~i5 ",:~C':.,' ;< ~ )~:F1 :Pc' :Jt ~;~~ 66 )>c u ~ ~ 1'0 :0 C;t\ -< ..1"J!!!: ~.~.,,~ ~._ J iJjM~~..,----", .~:~_~.'n". - 'I "~.~fl~:" -_ " '.' . ~:tib ... ,.,.. . "1 MICHAEL D. BLESSING, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 7072 Civil Term 2001 CYNTHIA L. BLESSING, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT AND NOW, this January 3, 2002, I, Jane Adams, Esquire, hereby certify that on December 22, 2001, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Cynthia L. Blessing 329 N. Hanover St. Carlisle, Pa. 17013 DEFENDANT Respectfully Submitted: an Adams, Esquire J.D. o. 79465 11 outh Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -"-,'_"iN"<'-l'i<!'J.,, , , -"".",,,0 ','.r .,,', ~-" " , ,,~ ;'" ,,-, , I ----.."""'' , ~ -, ~ =, ,~,~.~ ,,,.,, ""'-"= '0'" -~, -.". 7,,,,,~';l,,".<~'"~'~.~~'" [,.-~~':'~:li')lfni'L'?T'-?-:";:;o: ... "" CI 0 Ci C N -'1 <::.. , -Oc;.:! :pp .. OJ~: -"'. t'-:-" - ~~; I .~:~S Q:) 3-~i ~.o;-... !<C) -n -.-",; r~"", =: ~5~~ 2-' c 'i': " ~ .....c" "" 7' ~ 0 ::< (;.) io ' Complete items i;2,+anda. Aiso complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. R Attach this: card to the back of the mailpiece, or on the front ~f space permits. 1, Article Addressed to: ~~ L, 8!e~<Jd,{J 32-9fV. ~ " ~Pf+17DI3 E0 811 2. Article Number (Transfer from seNies laOOO PS Form 3811, March 2001 70G0/~ 70/)OC;f! h1?D /77d-. 1O.2~..()1~M,1424~ Domestic Return Receipt x D. Is deliv ry address different from item 1 If YES, enter delivery address below: 3. o Express Mail o Return Receipt for Merct:Jandise DC.C.D. 4. Restricted Delivery? (Extra Fee) ;<1,,,,,,,~,;I= , ,~.~..... ~" '~ .=~~~~~I~~.[j,,~!JJJj~_l'f<lJ~~lUf,J~-,rlnlllfl:'r"""-"~'~''''~~~~~,~:~;."ti~"i;f~~~~"~IJ:!!Y~r-_~":'~7'~ i~LJ >, . MICHAEL D. BLESSING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY CYNTHIA L. BLESSING, Defendant : NO, 01-7072 CIVIL TERM PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter the appearance of the Family Law Clinic on behalf of Cynthia L. Blessing, the Defendant, in the above captioned matter. Date: January 30, 2002 ~Af",~ Lily L. Cheung Certified Legal Intern ~LN- S M. PLACE ROBERT E. RAINS TERl L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ':", ~jJll ,'," -.' ""-~,,,j:<f!;"-"'~' ,-~"""';~"",:'"C_-ci,'.'~~ '1'-'i'V,,,p~^l--w,;~ "', _,,,,_,,,,,,,.-~c,',",_~_,",_'" __~ .",,' >~, "l"_',__.,~,_ C","__-'-," ,,~,_~ ,_._" ,^ "" .., '" "..,,~.. _ y _,,_.. ~,,"~~~_ d"" . '. MICHAEL D. BLESSING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY CYNTHIA L. BLESSING, Defendant : NO. 01-7072 CIVIL TERM CERTIFICATE OF SERVICE I, Lily L. Cheung, of the Family Law Clinic, hereby certifY that I am serving a true and correct copy of the Praecipe to Enter Appearance on Jane Adams, Esq., at 117 South Hanover Street, Carlisle, Pennsylvania, 17013 by depositing a copy of the same in the United States mail, first class, postage prepaid, this 30th day of January, 2002. January 30, 2002 X9~' Ck Lily L. Cheung Certified Legal Intern ~ F AMIL Y LAW CLINlC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 "-'1~__, , -. -- , '):i';'i'--"-;:-:"\."-"__'_":~;'-';_ '>" ':"-!-' ,-" ""--;';'::."'-','-""-1'-,-: "c,"-~" ~.- -.~,- '-'1' ,--" ".y, "~- > -- ~~ ~'- 1l~1,~____,^ ,-" - .7< '" ",1"'r~" ".,..- '"" " -~ ~" .~" ,.', W';~'" '"c~' - -~" - o ~~ -00:: mn; Z:T 0~~ r.::c' "'" ::;:("".J Fe) :Pc ;:: -~ -< .r --~'''t o l~~.) ~~~ , :'C_r;t- 'I ~i -:-~t~~ ~1'~~ u -..j ~ '< 0) (:J ~ >D N -.l G' Pf/ ~-'~~r-: ;:'o,,:,~~~~';!j:;;;>J!~~~"'}"~~-,-:J1\ 1\'~Kn~~~~~I_~::-.)~ , I = ~ JAN 11 2002 t MICHAEL D. BLESSING, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANlA v. : CIVIL ACTION - LAW : IN CUSTODY CYNTHIA L. BLESSING, Defendant : NO. 01c7072 CIVIL TERM CUSTODY AGREEMENT AND ORDER TillS AGREEMENT, made this ID'*" day of January, 2002, between Cynthia L. Blessing ("Mother") and Michael D, Blessing ("Father"), concerns the custody of their children, Noah M. Blessing, born January 31,1991, and Harley D. Blessing, born Jilly 15, 1993. Mother and Father desire to enter into an agreement as to the custody of their children. Mother and Father agree to the following: 1. Mother and Father shall share legal custody of Noah and Harley. 2. Mother shall have primary physical custody of Noah and Harley. ) 3. Father shall have partial physical custody of Noah and Harley as follows: a, Father shall have physical custody of Noah and Harley every other weekend (during the days), beginning January 12,2002, on Saturday from 9:00 a,m. until 3 p.m. and Sunday from 9:00 am. unti13:00 p.m.. During Summer vacation from school, Father's weekend hours shall be 9:00 a.m. until 4:00 p,m.. b. Father shall have physical custody of Noah and Harley every other Thursday, beginning January 17,2002, from 5:00 p.m. until 7:00 p.m.. During Summer vacation from school, Father's Thursday evening hours 1 ~'<>-'-;;l<'!i~1<."",_"<"". __ _,," ,~ -- ~- -~ ,'? '" ,--- - . ~~~ - -~ " ~7Tl!mi'" " ~'~c." _ ,~ "~ -o'f.'"'C'l(io,,,< ., - --~ shall be 4:00 p.m. unti18:00 p.m.. c, Holidavs. The holiday schedule shall supersede the normal custodial schedule. 1. Birthdavs. Mother shall have physical custody of both Noah and Harley on each child's birthday until3:00 p.m.. Father shall have physical custody of both Noah and Harley on each child's birthday from 3:00 p.m. until 8:00 p.m., 2. Thanksgiving. Mother shall have custody of Noah and Harley on Thanksgiving Day until 3: 00 p.m.. Father shall have physical custody of Noah and Harley on Thanksgiving Day from 3:00 p.m. until 8:00 p.m.. 3. Christmas. Mother shall have physical custody of Noah and Harley on Christmas Day until 2:00 p.m.. Father shall have physical custody of Noah and Harley on Christmas Day from 2:00 p.m. until 8:00 p.m.. 4. Easter. Mother shall have physical custody of Noah and Harley on Easter Sunday until 3:00 p.m.. Father shall have physical custody of Noah and Harley on Easter Sunday from 3:00 p.m. until 7:00 p.m.. 5. Fourth of Julv. Mother shall have physical custody of Noah and Harley on the Fourth of July after 2:00 p.m.. Father shall have 2 .' ,~I~ "T:", _'" 0 - '," , . 1""- ~;'_'"~~~f(!li1''''' -" - OOr" "--- physical custody of Noah and Harley on the Fourth of July from 9:00 a.m. until 2:00 p.m.. 6. Mother shall have physical custody of Noah and Harley each Mother's Day, and Father shall have physical custody of Noah and Harley each Father's day from 9:00 a.m. unti13:00 p.m.. d. Other times as agreed by the parties. 4. Mother and Father shall be entitled to reasonable telephone access with the children while the children are in the other's custody, 5. Mother and Father shall notify the other of all medical care any child receives while in that parent's care. Mother and Father will notify the other immediately of medical emergencies that arise while the children are in that parent's care. 6. Neither parent will do anything that may estrange either 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 children's love and respect for the other parent. 7. Transportation shall be shared as agreed by the parties. 3 ~'7.'WP,," _, ^, -~" ~,', Ir" - - , ," ,~ "-..,.~ ~~. , -~-"" ;,., Tn" ~ ~ - - 8. The parties intend to be bound by the terms of this Agreement and jntend for this Agreement to be made an Order of Court. (~)~~ -;;ichael D BI g, Plaintiff / J e Adams, Esquire 17 South Hanover Street Carlisle, PA 17013 717-245-8508 Counsel for Plaintiff , )j~J!!:f%l4lMlt \. Michelle L. And Certified Legal Intern for Defendant ~PLA{;l ROBERT E. RAINS TERI L. HENNING Supervising Attorneys vF AMIL Y LAW CLINlC 45 North Pitt Street Carlisle, Pa 17013 717-243-2968 ORDER AND NOW this /I ~ day of '1 t?" iJ a...-; , 2002, the above Custody Agreement is approved and entered as an Order of Court. I L ~ 1Yl;,J,J 01 -11"02 p.~s ff~ J. 4 F'!0~~;';;l, -.,1. - ~"""" ~:."" :{,,,'.,, T"~', ,'.. ""," "'<","c'"(," - "', ,'. .-, '~~I/..~ e' ",'.--' "'t_,-=,'~""'" " .-~,"'~-''''' . ~ ./,~,..-,- CAe'- -0, ~_. , ,.___ ", c '''f."~,, 'F' 'q '" -:,>,. . . ~''f-:. r.' . VIN\;'\I,~SNN3d ! r ~ 'f"". '""r' r.',__ All\!! II ! ) , ...~'" d :-.r1''-'lill''''\ , ,J J",~.',._, " I': I ,t."1 :'):::;;'\1 1-...} :::; I :Or 1111 v .'\ if rr I IN! ;~D AUV1C!, 3D , .~^" -,K.-J. " """"" . .. .." m'~~'~,'n'""''''lnTlmr[i;il'l1' 'T'rifll'!FtIi""'r~"Ir"''''r''r','i' . .- -... ,., , ,. '_'.,,,~ ,.:=I!!l~~W~~JI\1~~~m:,;~~~ ~""~~f '_ r~lIjI~t.)_~.~~,;' ;ltx1_ --, ryl\" · 5) 7""7 ' ~l"l,' ..;. , ""',, '",,,., yt- MICHAEL D. BLESSING, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW CYNTHIA L. BLESSING, Defendant NO. 01 -7072 CNIL IN CUSTODY COURT ORDER t, AND NOW, this // Y day of January, 2002, the conciliator being advised at the scheduled custody conciliation conference that the parties have reached an agreement and will be submitting that agreement to the court by stipulation, the conciliator relinquishes jurisdiction. BY THE COURT, ~ Hubert X. Gilroy, E Custody Conciliato ""ffi'J'?,'!;\"1!i., - - ,"~' ,,"~ ,'.''-< -"",;-,-~.",,;', ].""~,'"''','''~',,,,.,, "'''~Ii'''''"'''--~'-'' ~ '''-''y", '_' ."'.,~ :1' .~ . "~_,'~T 'C -, --:,.---c,-'-.'' -h. ",_ _ "< I~' ~,T~J^ s o ::s -C -t- o c:t 'C ~ ~ \1 << ~ \ t" C'\ I -... ..~ ..."" .~~ "- ~--~- ",""~'''~'""",~~,,,, Vl!lT " o"f"_-'-~k"'\I,~ .,'C~""~ <'~ ',,~,~, ,.."'-'-'T-rn. :: 'oJ ~~".""T"~' u..1r~fIDW:~~-:'1)};~fY'11c;;'ff;;:t~~;'~f:'~ii ;:;;:s f3H - .~..c:'~~:,~~";~~~'~~l>~~'~$fl:-'~.~~~~~~~~.~!i!l!~~~; , 1J,:",,'(n. -, '"fr ~. '''--.~-' l:' .1'''' ..1--' "I ,-"",".,';,' '" v. . IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA . CIVIL ACTION - LAW . IN DIVORCE AND CUSTODY MICHAEL D. BLESSING, Plaintiff CYNTHIA L. BLESSING, Defendant . NO. 01-7072 CIVIL TERM CERTIFICATE OF SERVICE I, Lily L. Cheung, hereby certifY that on this 5th day of April 2002, I am serving a true and correct copy of the Affidavit of Consent, Waiver of Notice, and Praecipe to Transmit the Record, upon Ms. Jane Adams, attorney for Mr. Michael D. Blessing, at 117 S. Hanover St., Carlisle, PA 17013. 4tJril 5, J.€JO d-- , Date ~~'~ Lily L. Cheung Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, P A 17013 717-243-2968 ~ "~~" -" "^~ '. .~~~~,~,_ .".,~.~ ,___,~~, ""'""""""~4= _ .~. '.""~_ ~__""~,..",,,,', '''' ,',~,~,,~___".,""".~,,~ , ..- ,- "' " ,~ { ,~ ~ -,' ,--~"~v'--- '.~,.~"'~_~e. '~''''',-- .~ ,~. "^ '~;i-;--~,.~"":", '.'. ,,' ~"' ""."",<", ,~, -" -1. 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