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HomeMy WebLinkAbout01-6222IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KING, SR., Plaintiff JENELINE SAYSON KING a/k/a JENELINE SAYSON DIAZ, Defendant CIVIL ACTION- LAW No. 2001 - 6, ~.~-~ IN ANNULMENT 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 fights 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 Courthouse, Carlisle, Pennsylvania. 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. Court Administrator Fourth Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200~ ~ Mighael J. Hanft, Esftuire Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 F:\Vs~r Folder~Film Docs\Gendoc~20Ol\10os-2noticeldefendwpd Attorneys for Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KING, SR., Plaintiff JENELINE SAYSON KING afl~/a JENELINE SAYSON DIAZ, Defendant CIVIL ACTION - LAW No. 2001- ;o: IN ANNULMENT COMPLAINT IN ANNULMENT AND NOW, this ~ qtY' day of ~' ~ r~,~t'~- ., 2001, comes Plaintiff, RICHARD LEE KING, SR., by and through his attorneys, the Law Office of Michael J. Hanft, and files the following Complaint in Annulment, and in support thereof avers as follows: 1. Plaintiff is Richard Lee King, Sr., (hereinafter "Plaintiff'), who has a mailing address of P.O. Box 52, Boiling Springs, Cumberland County, Pennsylvania 17007. Plaintiffhas resided in Cumberland County since 1951. 2. Defendant is Jeneline Sayson King a/k/a Jeneline Sayson Diaz (hereinafter "Defendant"), whose last known address is 308 North Frederick Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiffhas been unable to locate Defendant since on or about June 16, 2000. 4. Plaintiffhas been a bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint in Annulment. Phillipines. Plaintiff believes and therefore avers that Defendant is a resident of the 6. Plaintiffis a citizen of the United States of America. 7. Plaintiff believes and therefore avers that Defendant is a citizen of the Phillipines. 8. Plaintiff and Defendant were man/ed on June 8, 2000 in Carlisle, Cumberland County, Pennsylvania. A copy of Plaintiff and Defendant's Marriage Certificate is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof. 9. There have been no prior actions in divorce or annulment between the parties. 10. Plaintiffbelieves and therefore avers that said marriage between Plaintiff and Defendant was procured by the Defendant through the use of fraud and coercion insofar as Defendant entered into this marriage for the sole purpose of obtaining a temporary visa and gaining admittance to the United States of America, as evidenced by the fact that the marriage lasted only eight (8) days. 11. Plaintiff has had no telephone, mail, personal, or e-mail contact with Defendant since on or about June 16, 2000, when Defendant returned home fi'om work only eight (8) days after being married, to find a note from Defendant stating that she had left him. A copy of Defendant's Note is attached hereto as Exhibit "B" and by reference incorporated herein and made a part hereof. 12. Plaintiff has, on numerous occasions, attempted to contact and locate Defendant, but all attempts have been unsuccessful. 13. Plaintiffhas 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. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 14. Neither Plaintiffnor 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. WHEREFORE, Plaintiff requests that the alleged marriage between himself and the Defendant be deemed null and void, and that the Court enter a Decree of Annulment. Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT Attorney I.D. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff VERIFICATION The foregoing Complaint in Annulment is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint in Annulment and to the extent that the document is based upon information which I have given to my counsel, it is tree and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. arriage ( eriifira OF ~ , TWO THOUSAND AT I~ ' ' WERE BY ME ~ c.~arriage IN ACCORDANCE WITH LICENSE ISSUED BY /~/JARY C. LEWIS, CLERK OF THE COURT OF COMMON PLEAS, ORPHANS' COURT DIVISION OF  CUMBERLAND COUNTY, PENNSYLVANIA. (Original No. 410 _ ~ooo /) VOL, ~ · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KING, SR., Plaintiff V. JENELINE SAYSON KING a/Ma JENELINE SAYSON DIAZ, Defendant CIVIL ACTION - LAW No. 2OO1- 1 IN ANNULMENT MOTION FOR SPECIAL ORDER DIRECTING SERVICE BY PUBLICATION AND NOW, this ~f//t day of October, 2001 comes Plaintiff, RICHARD LEE KING, SR., by and through his attorneys, the Law Office of Michael J. Hanft, and pursuant to Pa.R.C.P. No. 430(a), moves this Honorable Court for a Special Order permitting the service of the Complaint in this action by publication in one (1) legal publication, The Cumberland County Law Journal, and in one (1) newspaper of general circulation within Cumberland County. In support of this Motion for Special Order Directing Service by Publication, the Plaintiff avers the following: 1. Plaintiff is Richard Lee King, Sr., (hereinafter "Plaintiff"), who has a mailing address of P.O. Box 52, Boiling Springs, Cumberland County, Pennsylvania 17007. Plaintiffhas resided in Cumberland County since 1951. 2. The last known address of Jeneline Sayson King, a/k/a Jeneline Sayson Diaz (hereinafter "Defendant") is 308 North Frederick Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. It is believed and therefore averred that Defendant is still a resident of the Philippines and therefore has no Social Security number. 4. The instant action concerns the armulment of a marriage between the parties entered into, under false pretenses by Defendant, on June 8, 2000 in Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff believes, and therefore avers, that Defendant entered into the marriage with Plaintiff for the sole purpose of obtaining a temporary visa and gaining admittance into the United States of America. 6. Plaintiff and Defendant were married for only eight (8) days when, on or about June 16, 2000, Plaintiff came home from work to find a note from Defendant stating that she had left him. She left no forwarding information. A copy of the note is attached hereto as Exhibit "A" and by reference incorporated herein and made a part hereof as if fully set forth herein. 7. Plaintiff has had no telephone, mail, personal, or e-mail contact with Defendant since receiving the note referenced in Paragraph 6, above. 8. No attempts have been made to serve the Defendant with the Complaint in Annulment at Defendant's last known address, which she shared with Plaintiff. While same would comply with the procedures as set forth in Pa.R.C.P. No. 402, all efforts would be futile and unsuccessful due to the fact that during her short-lived stay in Cumberland County, Pennsylvania, Defendant never established a mailing address (other than living with Plaintiff) nor did Defendant leave any forwarding information for Plaintiff nor with any branch of the United States Post Office. 9. Plaintiff has attempted to contact and locate Defendant via e-mail and through contacting friends' of Defendant, but all attempts have been unsuccessful. 10. Defendant has no family, friends or acquaintances, other than those referenced in Paragraph 9, above, known to Plaintiff of whom Plaintiff could inquire as to Defendant's current whereabouts. 11. To the best of Plaintiff's knowledge, Defendant did not work during the eight (8) days she was living with Plaintiff in Mechanicsburg, Cumberland County, Pennsylvania. 12. Plaintiffhas attempted to obtain a telephone number for Defendant via directory assistance but all attempts have been unsuccessful. 13. Neither the Cumberland County tax records, the Sprint Cumberland Countywide telephone directory, nor Cumberland County Voter Registration records show any record of Defendant's existence. A copy of the relevant pages of the Sprint Cumberland Countywide telephone directory is attached hereto as Exhibit "B" and by reference incorporated herein and made a part hereof. 14. A federal Freedom of Information Act request to the Boiling Springs Post Office was returned with the information that there is no record of Defendant. A copy of the FOI response is attached hereto as Exhibit "C" and by reference incorporated herein and made a part hereof. 15. To the best of Plaintiff's knowledge, information and belief, 305 North Frederick Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 was the only known address used by the Defendant during their brief time together. 16. Plaintiffhas made a good faith effort to locate Defendant in order to serve her with the Complaint in Annulment in this matter, but has been unsuccessful. The Affidavit in Support of Plaintiff's Motion for Special Order Directing Service by Publication is attached hereto as Exhibit "D"and by reference incorporated herein and made a part hereof. 17. Unless the Court allows service by way of publication, Plaintiff will be unable to maintain this action, will be prejudiced thereby, and injustice will result. WHEREFORE, Plaintiff, Richard Lee King, Sr., requests the Court enter a Special Order directing service of the Complaint on Defendant, Jeneline Sayson King, a/kfa Jeneline Sayson Diaz, by publication. Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT Attorney I.D. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff VERIFICATION The foregoing Motion for Special Order of Service by Publication is based upon information which has been gathered by me and my counsel in the preparation of the Motion for Special Order of Service by Publication. The language of the document is that of counsel and not my own. I have read the Motion for Special Order of Service by Publication and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Rictnard Lee King, Sr. OEIWEILER--OIEFFENBA'CH NE[LER David G 5542 Or~tQ~ Rd 0rW,....~ ............ 532-965]. LOCAL CALL NG NFO-SEE NF(~RM. ATION PA.GES IN FRONTOF DIRECTORY DEVDR AI~hMY J SS2 ~oxbu~ Rd Ship ............................ 532-2750 Ga~ L7500 Molly PItehff Hwy Ship .............................. J J) S St JQ~4'gd Lain .......................................... 763-1.t73 Jen S}B E Fort St Shrp ............................................. John J S624 Main LaJn ........................................... 697-~S].9 Kand)' K )SiS Orstwm Pd Ortw ................................. Katherine Mrs SJ r~ Pefl~ St Ship ................................ Madenx Mrs 6o w~nut SoUom Rd ShJp ...................... ~q524].10 Simuol K 21 Maple Ay WlbL ...................................... $32-2926 ThOllniS SBIC, Qrmoym Rd 0rbv .................................. DEVORE Beverly 97 Egt Dr C~s ..................................... 245-FI20 Lavr~ U ~,S ~ Lmgan An Ship ...................................... N L 200 PIr~ HHI gd CHS. .............................................. 245-2970 Robt E 402 Spree Sim ................................................... 9:39-2028 Rodnoy C 2o Ma~e Ay Wlb~ ........................................ 532-248~ Samuel N 40 W Main St With. .......................................... S30-~7~4 Sharon lg Maple Ln Nwvl .................................................. 776-0816 Wilbed G 419 Glenn Ay 61Sp ............................................ Wm H Jr 1B9 Pidge Hill Rd Mhr~ ...................................... 766-9852 DEVORIDK Diane 013 Market Ncum ................................. 774-3118 John T Jr h13 Ma~bet Ncum ............................................ 774-3118 John T 5r 2116 Cedar P~ Dr Cphl .................................... 737-9672 M L 2006 PHnctn Ay Cphl .................................................. 731-0401 DEVOS K 21-6 S ¥or~ Rd Mnhn ........................................... 796-1325 Sharon ~oe N West St Crls ............................................... 241-61J8 William F 807 Tomy gd Gdnr ......................................... 486-4761 DEVRIES David J ~76 H 28 Cphl ....................................... 761-7953 GeD 4162 Antelope Ct Hm&l ............................................... 726-9380 DEW Kimberiy A 6o8 Louisa L~ Hmdn .............................. 731-5616 DEWALD bray E ~12 Me,rd Allen Dr Mb~J ..................... 766.8736 DEWALL Thos N }0} Alle~v~ew Dr Mh~ ........................... 691-6600 DEWALT Alan Jr 15 Andbn Pke Dlbg ................................. 697-8606 Oarrell W 270 Me~dr, v Bd Nwvl ..................... ................... 776-6170 Dawn M 1o8o Creek Bd Cr(s .............................................. 258-4716 Oebra K 027 Cavelr~ St CHs~ ............................................. 245-9126 Donald W 2ol Fourth St Elsp ................................................................ 258-582~ Childr~'s TeMphone..-. .................................... .................... 256-5666 Dustin K 2?5 Meadows Rd Nwvl ........................................ 776-6584 Dustin K ~7o Meadow4 Rd Nwl ....................................... 776-6413 Eugene 1511 St Crts .......................................................... 249-5309 Hazel Wetzel 1 Bidge Dr Cds ........................................... 249-3991 John J Jr ~ ~tl AY Ship .................................................... 532-50].2 Uoyd A y110 Dickr~n An Cphl .......................................... 761-29].4 Paul Mrs 91416 th Ncum ................................................. 774-1287 Ralimrh 11801 Weaver Rd Or'~w ........................................... 532-4890 DE WALT Ray E 920 $ 2e Cphl ............. : ............................ 737-4876 DEWALT Robert 161o Longs Gap Rd Cr~s .......................... 258-8653 Thos 15 Andho Pke Dib6 ...................................................... 697-8606 William C 51 Echo Bd Cds ................................................ 249-4582 William S 927 Cavalry St Crts .......................................... 245-912h DEWANE Mark A 1~ w Locust Mbt9 ..............................796-9607 Wm 1~2 Old Ford Dr Cphl .................................................... 761-8246 Wm M 132 Old Ford Or Cphl .............................................. 761-6392 DEWAYNE Srafton 700 8~e2~d Or Mbr~ ......................... 766-8499 DE WEES Edna M 757 Pine Sltn,.....: ................................ 939-5887 DEWEES L U 516 Harding Ncum ........................................ 774-6132 Lauren A 61o Bidgeview Dr Dlbg ....................................... 432-0387 Ty 245 Hummel AY Lm~ ..................................................... 737-5547 DEWEY Diane K ~o N Sp~p9 St Ship ................................ S32.898S Fredk B ~h20 Lcgan Ct Cphl .............................................. 737-9897 James H & Va]erie S 215 Marn Wlvl ............................. 432-8485 Ralph J ~21 Roxbury 60 Ship ............................................. 532-5401 DEWIRE Mary Ellen 137-B Market Ncum ........................ 774-8485 Tiffanrany LB16 E Burd St Ship ............................................ 530-3180 DEWI~ ABg Dewalt Dr Sspg ............................................... 79Z-3991 D 59 Dewalt Dr S~,og ............................................................. 791-3990 Jennifer 20 Brtnon RP Ship .............................................. 477-8491 K 00 N Orate St C~s ......................................................... 240-0618 M 50 Dewalt Dr Ssp~ ............................................................ 791.3992 DEWITTE S J 722 Cumbrlnd Pt Crt Mbt9 ........................... 795-9627 DEWOLF G g Larken Ln Mhgp ............................................. 486-3332 Harold Thos 440 Uar~ Hun Rd N Cumberland ................ 774-1605 Joann M 440 Marsh Bun Rd N CumhoHand ....................... 774-1605 DEWOLFE W G 3rd Ncum ................................................. 774*7527 DEXTER D 6005 Mockingbird Dr Mbt9 ................................ 697-7143 Thos E ~L26 N 25 Cphl ......................................................... 763-6888 Wm P hODS Mockingbird Dr Mbrg ...................................... 697-7143 DEYA Janet 946 We~t~vle Rd Epnb ...................................... 732-7829 P 4070 Oai~ns Ct Hr~q ..................................................... 728-1328 Path 4070 Caissons Ct Enoa ............ =**..**..: ......................... 732-9083 DEYHLE DaM E 5145 Trimtite Rd Mbr~ .............................. 697-6781 Karen F S145 Trindle Bd Mbt9 .......................................... 697-678]* DEYLE B }65 Market Hspr ................................................... 986-].1S6 J yes Market Hspr ............................................................... 986-1186 DEYO David C 26 Hoover Bd Cr~s ........................................ 243-3753 George 11~ Dave Hill Dr Crl$ ............................................ 249`2664 OEZAGOTTIS Jas J go~ Bohort Mbt9 .............................. 766-8351 DHADIr B 47ol Brian Bd Mb~J .............. ~ .......................... 76]*-0120 O'HAPPART W[lflam F 27B1 Spring Rca Cr~s .................... 243-1450 DHIR Krishna 5 524 Spring H~ Bd Cphl ........................... 730-9322 Sheila g~4 Bprl~ Hse Rd Cphl ....................................... 730-9322 DIAAELD[N Abraham 4e E Penn St Crls .......................... 2q3-5814 D[AFERIO L 117 E Burd St Sh~p ........................................ 477-0331 D~AK Donald R 17 E Greenhouse Rd DIb9 ......................... 432-2081 DIAL Cortez Cas & Joycl 68 Garrison Ln Crib ................ 241-965]* L 4202 Nantckt Dr Mbrg ........................................... :.........732-4793 Laura Mrs ~! Race Hspr ................................................... 939-3877 DIAMANT V B6 Mooredale Rd CrlS ...................................... 2]*6-5758 DIAMOND A E 4006 Rosmnt Ay Cphl ................................. 737-S598 S G 485 E EImwd Av Mbrg .................................................. 766-04]*2 DIAMONDSTONE J 11oo N Pitt St Crte. ........................... 241-6473 DIANA R ~4o S washogt~ ~br9 ........................................... 795-].976 DLAS Alex Z251 Orcha~l Rd Lain ................... D~ Adl177 Wa~r M~r DI~ .......... ~ ............... 432-33~ Rlch~ AMh~y 27 B~ O~ D~ ....................... D~BERARDINE BUI $ ~7 ~d~ Dr Cd~ ........................ DISE~ H J~ffrly ~ W R~ ~d 01~ ........................... 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Clr Uh~ ....................................... 766-6188 rymond C 17 E Countryside Dr Bisp ............................... 240-0286 ,bt W 204 S lg th CphJ ................................................. 731-9404 ,bt W 204 S ~9 Cphl ..................................................... 731-9404 dd A ~ E 5pringville Rd BISP ......................................... 241-.f685 ~4 Tunbrid~ Ln Crls ........................................................ 141-075S dORE E R 2~! York Rd Cr~s ......................................... 245-2125 ]04 Yverdon D~ CPhi .................................... 761-1138 ~a 6g Aspen Rd Dib~ ............................................. 432-].7S4 LOCAL CALLING INFO-SEE INFORMATI. ON,PAGES IN FRONT OF DIRECTORY KIMBERUN g L 8]0 wm~lrtd~ Or hi~ .......... ~...........939.40~5 KIMBLE ROM R 7DS AJllm Ay Mb~ ..................... 7~ ~ME Br~liy A 26 ~ Rd C~l ....................... -761-~95 OonMd P 6 w C~ ct CH~ ........................ RonaldA 4~7 cam~ Sim ......................... 93~1701 B J 6 ua~ ~ Mb~ ...........................................697~ KING Alan ] AIt~na Alvq# H 121S H~r St Cd~-. ......... 249~ Ann ~? Ph~nt Ct ~ ~ ....... 79S-~ Cha~es E 2000 w~ Gap Rd CH~ .............. 249-~ HayDEn G 2'i12 E hiarket C~I ....................................... 761-6340 I~n M icc Sandbank Rd MhSp ............. 486-7107 He ....... 737-39].2 Hear R 9o09 Cherokee AY Cphl ................... y ......... 732-4706 Hen R Ji' ~o victra Way Cphl ......................................... 9 Jennifer ,25 8a imore St OIb9 ........................................ Uncoln 909 To.va, R~l Gdnr ............................................ 7~2~6.45~5~9 ASr .,0 William 4~.53 CaHisle Rd M H 800 EIkV~ Dr NcUm ............................................... M L 1023 4 · Ay 0biCL ........................................................ Malcolm L 37 Phe~t Ct Lain ......................................... Marian H 10 Drexel HILl Cir Dr NcU~ ............................... Mark L F 892 HaW~onv Ay Ubr~ .................................. Maur[¢e P 33, 4 Hcum ............................................... Michael A & Unda R 045 Ridge Rd Ship ..................... Michelle 2203 Cedar Ru~ Dr 1.3 Michelte 34 SI Paul S 3 Ronaid W S J tO T 732-885]. RE~IDENTtAC'USTINGS , , · Ig#G--KISNER 15:: K~RKLANO ............ Oougt~ 12o~ ~. ' .................. 4~2-57~ Mirk O 27 ~l i~.~ ~9 Pe~ Dr BI~ .......... 24~3752 RK~GHTER ~n .... ~7~7: ~ussell E Jr 107'~ .i9~ NSINGER AMW 2917 NSLER NSLEY NTER Rat h I Je Unda Timoth K~RMES Scott A 2 KIRSCH Ca~ 1~ OouglaS KIRTI~'Y M E 2~ Kowe~ K~RWAN J E 1217 Gm- Gladys R 429 Lev~br~ Rd L A 628 Eppt~ M R 17o8 pat~ WmF: Chis E Mrs ........ 200 N Front W~g ................. '~=': ................. ... 763-4C MICHAEL ]. HAN~=T GREGORY H. KNIGHT August 22, 2001 I~..ICHARD L. WEBBER* JR. Postmaster 702 East Simpson Street Mechanicsburg, PA 17055 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: ~J neline Sason Diaz Address: ~t Mechanicsbur PA 17055 NOTE: The name and last known address are reqmred for change of address mformaUon The name, ~fknown and post office box address are requixed for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacityofrequester (e'g'' pr°cess server' att°mey' party representing himself): Attome :MichaelJ. Hanf~ Es uire 2. S~atut; or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pri~ se o except a corporation acting pro se must cite statute): N/A _ LAW OFFICE OF MICHAEL J. HANFT ATTORNEYS & COUNSELLORS AT LAW OF C~ QU~N.~ E~L. WILLIAM A. ADOAM$ MICHAEL R. RUNDL[ 3. The names of all known parties to the litigation: Richard Lee King, Sr., Plaintiff; Jeneline ~~ SasonDiaz Defendant 4. The court in which the case has been or will be heard: Cumberland County Court of Common Plea._._~s 5. The docket or other identifying number if one has been issued: Not yet issued due to inability ~in with the Corn laint 19 BP. OOKWOOD AVENUE SUITE 106 CARLISLE. PA 17013-9142 717.249.5373 FAX 717.249.0457 ~VV'fW'HAN~TLAWFIRM'COM Postmaster August 22, 2001 Page Two 6. The capacity in which this individual is to be served (e.g., defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION COLrLD RESULT IN CRJ/vlINAL PENALTIES INCLUDING A FINE OF LIP TO $10,000 OR IMPRISONMENT OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used olely for service of lc 1 rocess in connection with actual or prospective litigation. ~a~/~) 19 Brookwood Avenue, Suite 106 Si Address Michael J. Hanft, Esquire Printed Name Carlisle, PA 17013 City, State Zip Code FOR POST OFFICE USE ONLY No change ofaddress order on file. Notknownat address given. '~vloved, leR no forwarding address. No such address. NEW ADDRESS or BOXHOLDER'S NAME and STREET ADDRESS POSTMARK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KING, SR., Plaintiff JENELINE SAYSON KING a/k/a JENELINE SAYSON DIAZ, Defendant CIVIL ACTION - LAW No. 2001 - IN ANNULMENT AFFIDAVIT IN SUPPORT OF PLAINTIFF'S MOTION FOR SPECIAL ORDER DIRECTING SERVICE BY PUBLICATION I, Richard Lee King, Sr., being duly sworn according to law, deposes and says the following: 1. I am the Plaintiff in the above action. At my direction an investigation was conducted into the whereabouts of the Defendant. The unsuccessful efforts to locate the Defendant included the following: a) b) Attempts to contact Defendant via e-mail; Attempts to locate the Defendant's telephone number via directory assistance; c) d) Attempts to locate Defendant's forwarding address via Cumberland County tax records, the Sprint Cumberland Countywide telephone directory, and the Cumberland County Voter Registration records; Attempts to locate Defendant's forwarding address pursuant to the federal Freedom of Information Act; e) 0 An internet search; Attempts to contact friends' of Defendant via email and telephone to determine if they have any knowledge of Defendant's whereabouts; and g) Filing of a Police Report with the Mechanicsburg Police Department. I have been unable to locate any addresses for Defendant other than her last known address at 308 North Frederick Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. Defendant's last known address was my address and therefore, no efforts have been made to serve Defendant at that address as she is no longer living with me. The stated address is the Defendant's true residence to the best of my personal knowledge, information and belief because she left me no forwarding address or means by which to contact her, nor, to my knowledge, has she attempted to contact me. The allegations in the foregoing Motion for Special Order and the attached Exhibits are true and correct to the best of my personal knowledge, information and belief. Richard Lee King, Sr. ~ '~ Notary Notafla Seal Denise L. Nye, Notary Public ~outh Mlddleton Twp., Cumberland Cou _n~y My Commission Expires Feb. 26, 2005 Menlioer, Pennsylvania As,~ocis~ion ot Notaries IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KJNG, SR., Plaintiff JENELINE SAYSON KING a/k/a JENELINE SAYSON DIAZ, Defendant CIVIL ACTION - LAW No. 2001 - IN ANNULMENT ORDER GRANTING MOTION FOR SPECIAL ORDER OF SERVICE BY PUBLICATION AND NOW, this ,~,~t~ day of ]~ ~,a~ , 2001, upon consideration of the Plaintiff's Motion for Special Order Directing Service by Publication upon Defendant, JENLINE SAYSON KING a/k/a JENELINE SAYSON DIAZ, pursuant to Pa.R.C.P. 430(a), and it appearing to the Court that the Plaintiffhas made a good faith effort to locate and serve the Defendant in the regular course, it is hereby ORDERED and DECREED that said Motion is granted, and service upon the Defendant, JENELINE SAYSON KING a/k/a JENELINE SAYSON DIAZ is to be made by publication in the Cumberland Law Journal and in one (1) general circulation newspaper in Cumberland County. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KING, SR., Plaintiff JENELINE SAYSON KING a/k/a JENELINE SAYSON DIAZ, Defendant CIViL ACTION - LAW No. 2001- ~ ~4¥il IN ANNULMENT NOTICE OF COMMENCEMENT OF AN ACTION IN ANNULMENT TO BE SERVED BY PUBLICATION PURSUANT TO CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1009-1 TO JENELINE SAYSON KING affda JENELINE SAYSON DIAZ: You are hereby notified that Plaintiff, RICHARD LEE KING, SR., has commenced an Action in Annulment against you entered to 2001- in the Court of Common Pleas of Cumberland County, Pennsylvania, which you are required to defend. By: Sheriff LAW OFFICE OF MICHAEL J. HANFT Attorney ID No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Attomeys for Plaintiff 0~o~ Iq IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KING, SR., Plaintiff CIVIL ACTION - LAW v. No. 2001 - 6222 Civil Term JENELINE SAYSON KING a/k/a JENELINE SAYSON DIAZ, Defendant IN ANNULMENT CERTIFICATE OF SERVICE AND NOW, this 17th day of December, 2001, I, Michael J. Hang, Esquire, hereby certify that pursuant to the Order Granting Motion for Special Order of Service by Publication issued November 5, 2001 by the Honorable Edward E. Guido, I have served Jeneline Sayson King a/k/a Jeneline Sayson Diaz, with Notice of the Complaint in Annulment by Publication in both the Cumberland Law Journal and The Sentinel. A copy of the Proof of Publication for the Cumberland Law Journal is attached hereto as Exhibit "A". A copy of the Proof of Publication for The Sentinel is attached hereto as Exhibit "B". LAW OFFICE OF MICHAEL J. HANFT Attorney I.D. No. 57976 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 F ~u~,r Vo:~.~,ooc~c~aoc,2oo~x~oo~_~ ~ ~.~,~,~ ~,d Attomeys for Plaintiff PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND: SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the public'ation of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz NOVEMBER 23, 2001 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are Ro~tor -' SWORN TO AND SUBSCRIBED before me this 23 day CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN In the Court of Common Pleas of Cumberland County, Pennsylvania CIVIl Action--Law No. 2001-6222 Civil Term ' RICHARD LEE KING, SR., Plaintiff JENELINE SAY$ON KING, a/k/a JENELINE SAYSON DIAZ, Defendant NOTICE You have been sued in Court, If you wish to defend, you must enter a written appearance personally or by attorney, and file your defenses or objections In writing with the court. You are warned that ffyou fail to do so, the case may proceed with- out you and a decree of annulment may be entered against you by the Court. A Judgment may also be en- tered against you for any other claim or relief requested in the Complaint In Annulment by the Plaintiff. You may lose money or property or other rights Important to you, including custody or visitation of your chil- dren. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROP- ERTY, LAWYER'S FEES OR EX- PENSES BEFORE AN ANNULMENT IS GRANTED. YOU MAy LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS NO- 'rICE 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 Avenue Carlisle, PA 17013 (717) 249-3166 MICHAEL j. HANFT, ESQUIRE LAW OFFICE OF MICHAEL J. HANFr Attorneys for Plaintiff 19 Brook'wood Avenue Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 Nov. 23 2 State of Pennsylvania, County of Cumberland. PROOF OF 15UBLICATION Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication NOTICE OF ACTION IN ANNULMENT In the Court of Common Pleas ol ' ~ Cumberland County Pennsylvan a C v Action-Law No. 2001-6222 Civil Term RICHA~G. SR.. PJarntiff vs. JENELINE SAYSON KING a/K/a .IENELINE SAY, SON DIAZ. Defendant NOTICE You have been sued ~n Court. If you wish to defend, you must enter a written appearance persOnally or by attorney, and file your defenses or objections in writing with the court. You are warned that if you fail tO do so, the case may proceed withou you and a decree of annulment may be en ered aga nst you by the Co'urt. A judgement may also be entered e arnst you for any oth- er claim or relief reques ed In.the ~omplain! in' Annulment by the Plaintiff. You may lose money or prop. arty or other rights importan o you., Including custody or visitation of your children. - IF YOU DO FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY. LAWYER'S FEE5 OR EXPENSES BEFORE AN ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS NOTICE 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 Avenue Carlisle, PA 17013 (717)249-3166 Michael J. Hanft, Esquire ' LAW OFFICE OF MICHAEL J. HANFT , 19 Srookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717)249-5373 ' Attorneys for Plaintiff ' November 16, 2001 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. November 21, 2001 Sworn to and subscribed before me this 21st day of November ,2001. ~'No~ary Public My commission expires: f Notarial Seal Wend,/L. Metzger NCary Pub c Carlisle Boro Cumberland Cou~n,'y My Corem ssion Expires June 2, ~C05 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA R/CHARD LEE KING, SR., Plaimiff JENELINE SAYSON KING a/k/a JENELINE SAYSON DIAZ, Defendant CIVIL ACTION - LAW No. 2001 - 6222 Civil Term IN ANNULMENT CERTIFICATE OF SERVICE AND NOW, this 4th day of March, 2002, I, Lindsay Gingrich Maclay, Esquire, hereby certify that I have served Jeneline Sayson King aYk/a Jeneline Sayson Diaz, with Notice of Heating in Annulment via Publication in both the Cumberland Law Journal and The Sentinel. A copy of the Proof of Publication for the Cumberland Law Journal is attached hereto as Exhibit "A". A copy of the Proof of Publication for The Sentinel is attached hereto as Exhibit "B". HANFT & KNIGHT, PC. L'/M~icha-el ~. l~a~ff, E~uire ! Attorney I.D. No. 57976 Lindsay Gingrich Maclay, Esquire Attorney I.D. No. 87954 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff Exhibit "A" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 STATE OF PENNSYLVANIA : : COUNTY OF CUMBERLAND : SS. Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz FEBRUARY 22, 2002 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general cimulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are itor ~ SWORN TO AND SUBSCRIBED before me this 22 day of FEBRUARY, 2002 LO~S E. SI~DER~ H~afy Public / CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County. Pennsylvania Civil Action--Law No, 2001-6222 RICHARD LEE KING. SR.. Plaintiff JENELINE SAYSON KING, a/k/a JENELINE SAYSON DIAZ, Defendant IN ANNULMENT NOTICE OF MASTER'S HEARING TO: JENELINE SAYSON KING, a/k/a JENELINE SAYSON DIAZ A hearing in regard to the above- referenced matter has been sched- uled for Tuesday, April 16, 2002 at 9:00 a.m. in the office of Divorce M~ster E. Robert Elicker, 1I, which is located at 13 North Hanover Street, Carlisle, Pennsylvania. You have been sued in court. If you wish to defend, you must ap- pear at the above referenced loca- tion at the above-referenced date and time. You are warned that if you fail to do so, the hearing will pro ceed without you and a Decree in Annulment may be entered against you the Court. A judgment may also be entered against you for any other claim or relief requested in the Com- plaint in Annulment by the Plaintiff. You may lose money or property or other rights important to you. in- cluding custedy or visitation of your children. IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DWISION OF PROP- ERTY, LAWYER'S FEES OR EX- PENSES BEFORE AN ANNULMENT IS GRANTED. YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS NO 'rICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, CO 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 MICHAEL J. HANFT, ESQUIRE Attorney I.D. No. 57976 LINDSAY G[NGRICH MAC LAy. ESQUIRE Attorney I.D. No. 87954 HANFT & KNIGHT, P.C. Attorneys for Plaintiff 19 Brookwoed Avenue Suite 106 Carlisle, PA 17013 9142 {717) 249-5373 Feb. 22 Exhibit "B" PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KING, SR., Plaintiff JENEUNE SAYSON KING aJkJa JENELINE SAYSON DIAZ, Defendant CIVIL ACTION - LAW NO. 2001-6222 INANNULMENT February 1R; 2002 leposes that he is not interested in ter of the aforesaid notice or .N.I~TIC E O_~ ~ ~ TO: JENELINE SAYSON KING a/K/a JENELINE SAYSON DIAZ and that all allegations in the A hearing in regard o the'above-referenced matter has been scheduled for Tues ~ent as to time, place and character day, April 16, 2002 at 9:00 a.m. in the office of Divorce Master E. Robert Elicker, II, which is located at 13 North Hanover Street, Carlisle, PennsyNania. re true. February 20, 2002 ~bscribed before me this 20th .2002. Notary Public You have been sued in court, if you wish to de end, you must appear at the above- referenced location at the above-referenced date and time. YOU are warned that if you fall to do so, the hearing w I proceed without you and a Decree in Annulment may be ene ed against you by he Court. A judgement may a so be entered against you for an other c aim or tel e reques ed in the Complaint in Annulment by the Plaintiff. You m~y lose money or .property or other rights important to you, including custody or visitation of your chddren. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE AN ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULO TAKE THIS NOTICE 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. CUMBERLANO COUNTY BAR ASSOCiATiON 2 Liberty Avenue Carlisle, PA 17013 --ebruary (717) 249-3166 Michael J. Hanft, Esquire Attorney t.D. No. 57976 ~ Lindsay Gingrich Maclay, Esquire Attorney I.D. No, 87954 HANFT & KNIGHT, P.C. 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 717) 249-5373 1 Attorneys for Pain iff My commission expires: NOTARIAL SEAL ,,~IIRLEY O. DURNIN, Notary Pub!ic Carlisle Boro., Cumberland Coum"/ I~ Commission Expires Aug 9, 2003 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KING, SR., Plaintiff JENELINE SAYSON KING a/k/a JENELINE SAYSON DIAZ, Defendant CIVIL ACTION - LAW No. 2001 - 6222 Civil Term IN ANNULMENT CERTIFICATE OF SERVICE. AND NOW, this 10th day of June, 2002, I, Lindsay Gingrich Maclay, Esquire, hereby certify that I have served Jeneline Sayson King a/k/a Jeneline Sayson Diaz, with Notice of Filing Master's Report via Publication in both the Cumberland Law Journal and The Sentinel. A copy of the Proof of Publication for the Cumberland Law Journal is attached hereto as Exhibit "A". A copy of the Proof of Publication for The Sentinel is attached hereto as Exhibit "B". HANFT & KNIGHT, PC. ~cha~l J. t0t/ft, Es~Itire k.- ~/~A~Jmey I.D. No. S7976 Lindsay Gingrich Maclay, Esquire Attorney I.D. No. 87954 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff Exhibit "A" PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 1(5, 1929), P. L.1784 STATE OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : Roger M. Morgenthal, Esquire, Editor of the Cumberland Law Journal, of thc County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by thc local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly thc same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz MAY 24, 2002 ~ Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are SWORN TO AND SUBSCRIBED before me this 24 day of_ MAY, 2002 CUMBERLAND LAW JOURNAL NOTICE In the Court of Comr~n Pleas of Cumberland County. Pennsylvania Civil Action--Law No, 2001-6222 Cl~l Term RICHARD LEE KING. SR.. Plaintiff JENELINE SAYSON KING, a/k/a JENELINE SAYSON DIAZ. Defendant IN ANNULMENT NOTICE OF FILING MASTER'S REPORT The Report of the Master has been filed May 14, 2002. and copies have been sent with this Notice to coun- sel of record and the parties. In accordance with P.R.C.P. 1920.55 within ten {10) days after the mailing of this Notice and Re- port Exceptions may be filed to the report by any party. If no Excep- tions are filed within the ten (10) day period, the Court shall receive the Report, and if approved, shall enter a Final Decree in accordance with the recommendations contained in the Report. /s/E. Robert Elicken Il Divorce Master May 24 Exhibit "B" PROOF OF' PUBLICATION State of Pennsylvania, County of Cumberland. Lori Saylor, Classified Advertising Manager of THE SENTINEL, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following dates, viz Copy of Notice of Publication O~E u~UJ~ May 20, 2002 Affiant further deposes that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. May 22,2002 Sworn to and subscribed before me this 22nd day of May _, 2002. Notary Public My commission expires: NOTARIAL SEAL SHIRLEY O. DURNIN, Notary Public Carlisle Boro., Cumberland County My Commission Expires Audi. 9, 2003 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RICHARD LEE KING, SR., Plaintiff JENELINE SAYSON KING a/k/a JENELINE SAYSON DIAZ, Defendant CIVIL ACTION - LAW No. 2001 - 6222 Civil Term IN ANNULMENT PRAEC1PE TO TRANSMIT TO THE PROTHONOTARY: It appearing that the Master's Report in the above-referenced case has been filed for ten (10) days, that at least ten (10) days have passed since a Notice of the Filing of the Master's Report had been published in both the Cumberland Law Journal and the Sentinel, that a Certificate of Service has been filed, that no exceptions have been filed to the Master's Report, that the costs have been fully paid and that all requirements of law and Rules of Court have been met, you are hereby directed to submit said case to the Court of Common Pleas of Cumberland County, Pennsylvania, at the next sitting thereof. Respectfully Submitted, HANFT & KNIGHT, P.C. 1J. ~r~ft, Fl~tuire O Attorney I.D. No. 57976 Lindsay Gingrieh Maclay, Esquire Attorney I.D. No. 87954 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff I, , Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, do hereby certify that the costs in the above-stated case, have all been paid, including the Mater's fee. Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~ PENNA. Plaintiff VERSUS J]~LINE SAYSON KING, &/k/a J~NELINE SAYSON DIAZ, NO. i2001-6222 (IN DECREE Defendant AND NOW, (Civil ~,-m) , 2002 , it iS ORDereD and Sro DECREED THat the alleged marriage between Richard L. Kin~,P~iAINtlFf, AND Jeneline Sayson s annulled. . , DEFENDANT, 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; N/A ATTEST: ~ j.