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Home My WebLink About87-0029IN R/~R COURT OF CC~ON PLEA~ CUMBERLAND COUNTY, P~NSYLV~NIA NO. 29 CIVIL 1987 IN DIVORCE IEI.EN P. KENYON, Plaintiff ARTHUR R. KENYON, De fendant PPJkECIPE TO TRANSMIT RECORD THE LAW FIRM OF KILLIAN & GEPHART 218 PINE STREET P. O. BOX 886 HARRISBURG, PENNSYLVANIA 17108-0886 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. ............................ Plaintiff Versus .............................. Defendant. No. 29 CIVIL 19 8'7 DECREE IN ~ -..~~D.(I V OR CE ~I AND NOW .... . .......... , 19 ..87.. it is dared and ,:, decreed that ~ ~. ~N~ON ' " °I ' Imnh and .............. ~ ~- ..-~X~. o~¢ ............................ P ' 'ff, o,,, ,,,~, uonas at matrimony. ~~/ are divorced fr ,,* ,i._ ~._ ",'"~ .... ~ ........................ , 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; ~" HELEN p. KENYON, Plaintiff ARTHUR R. KENYON, De fendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 29 CIVIL 1987 IN DIVORCE 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 201(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Service was accepted by the Defendant on the 12th day of January, 1987, by certified mail, return receipt requested, return receipt number P23 0186731. 3. (a) Date of execution of the Affidavit of Consent required by Section 201(c) of the Divorce Code: by Helen p. Kenyon, Plaintiff, on June 15, 1987; by Arthur R. Kenyon, Defendant, on June 17, 1987. Related claims pending: None· Dated: June 22, 1987 KILLIAN & GEPHART 218 Pine Street P.O. Box 886 Harrisburg, PA 17108 Attorneys for Plaintiff CL~4BERLAND COU~fY, PFA~SYLVkNIA NO. IN DIVORCE HELEN P. KE/~YON, Plaintiff R. KENYON, Defendant COMJPLAINT_ IN DIVORCE THE LAW FIRM OF LLIAN & GEPHART 218 PINE STREET P. O. BOX 886 HARRISBURG, PENNSYLVANIA )7)08-0886 LAW OFFICES KILLIAN & GEPHART HARRISBURG, PA HELEN P. KENYON, Plaintiff ARTHUR R. KENYON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ~ <~~-_~ / ?~ 7 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. 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 at the Cumberland County Courthouse, Carlisle, PA 17013. 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 of Cumberland County Cumberland County Courthouse 3 South Hanover Street Carlisle, PA 17013 (717) 249-1133 LAW OFFICES KILLIAN & GEPHART HARRISBURG, PA HELEN P. KENYON, Plaintiff Ve ARTHUR R. KENYON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. : : : IN DIVORCE COMPLAINT IN DIVORCE UNDER THE DIVORCE CODE OF 1980 1. Plaintiff is Helen P. Kenyon, who has resided at 221 East Locust Street, Mechanicsburg, Cumberland County, Pennsylvania for the last ten and one-half (10%) years. 2. Defendant is Arthur R. Kenyon, who has resided at 2145 Market Street, Camp Hill, Cumberland County, Pennsylvania for the last six (6) months. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 17, 1972, in Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces. 7. The Plaintiff and Defendant are both citizens of the United States. LAW' OFFI(~ES ~LLIAN & GEPHART 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Dated: December 30, 1986 Respectfully submitted, Ronda K. Kiser, Esquire KILLIAN & GEPHART 218 Pine Street P.O. Box 886 Harrisburg, PA 17108 (717) 232-1851 Attorneys for Plaintiff COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ) ) SS.: ) AFFIDAVIT HELEN P. KENYON, being duly sworn according to law, deposes and says that the facts contained in the foregoing Complaint in Divorce are true and correct to the best of her knowledge, information and belief. HELE~ P-. KENYON KILL1AN & GEPHART Sworn to and subscribed before me this~ day of ~c~ , 1986. Notary Public IN THE COURT OF COF~40N PLE~S CUMBERLAND COUITISf, PENNSYLVANIA NO. 29 Civil 1987 IN DIVORCE HELEN P. KENYON, Plaintiff ARTHUR P. KL%DfON, Defendant AFFIDAVIT OF SERVICE, THE LAW FIRM OF KILLIAN & GEPHART ::'18 PINE STREET P. O. BOX 886 HARF~ISBURG, PENNSYLVANIA 17108-0886 LAW OFDI~E$ ~ILLIAN 8c GEPHART HARRISBURG. HELEN P. KENYON, Plaintiff Ve ARTHUR R. KENYON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 29 Civil 1987 : : : IN DIVORCE AFFIDAVIT OF SERVICE I, Ronda K. Kiser, Esquire, hereby certify that a true and correct copy of the Complaint in Divorce was served upon the Defendant by certified mail, return receipt requested on the 12th day of January, 1987. The original signed return receipt, number P23 0186731 is attached hereto and made a part hereof. Dated: January 13, 1987 Ronda K. Kiser, Esquire KILLIAN & GEPHART 218 Pine Street P.O. Box 886 Harrisburg, PA 17108 (717) 232-1851 Attorneys for Plaintiff O 8HISHI: Cmlq)lete Items 1.2, 3. afld 4. &:Id your address In h'm "RETURN'FO" tlJaco oo fromm, so. (CONSULT PeSTUASUB FOe FUS) I"1 Slaw to udum and dm debered ............... ~,.~hm u whem. dm, md mdrm e~ deed~ .. 4. l'YP~r'~ SHMCE: * ARTICLE NUIdOER Ocoo ~'/D~TE OF DELIVEI~Y ./ 1'OSTMA~K ----- 8. Af~JtL'TSS:s:'S AOOJt~SS I~, ~'mmsm'J 7. UNAm. E TO OO.A~ ~ 7IL OIItI.OYEF8 I IN 1~ COURT OF CYiMMON PT RAS CUMBERLAND COUNTY, PSI~NSYLV~NIA NO. 29 CML 1987 IN DIVORCE KENYON ~ Plaintiff Ve ARTHUR R. IKt~ON, Defendant AFFIDAVIT OF CONSENT THE: LAW FIRM OF KILLIAN & GEPHART HARRISBURG, PENNSYLVANIA 17108-0886 HELEN P. KENYON, Plaintiff Ve ARTHUR R. KENYON, De fendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 29 CIVIL 1987 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section Divorce Code was filed on January 7, 1987. 201(c) of the 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. Dated:~z~ /~f /~ Sworn and subscribed to before me this /Tq~ day of ~u~ , 1987. ~J ' o~ar~ublic MARILYN M. KERTIS-COX, NOTARY PUBLIC My Commission Expires April 22, 1991 Camp Hill, PA" . Cumberland County IN THE COURT OF CO~4ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 29 CIVIL 1987 IN DIVORCE HELEN P. KENYON, Plaintiff ~ R. K~NYON, Defendant AFFIDAVIT OF CONSENT THE LAW Firm OF KILLIAN & GEPHART 2i8 PiNE STREET P. O. BOX B86 hARRISBURG, PENNSYLVANIA I?108-0886 HELEN p. KENYON, Plaintiff Ve ARTHUR R. KENYON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 29 CIVIL 1987 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 201(c) of the Divorce Code was filed on January 7, 1987. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. 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. S4904 relating to unsworn falsification to authorities. Sworn and subscribDd to before me this ~ ~ ~'t. day of ,-~ ~-- , 1987. o~a~ Public BERNICE M. LINSENBACH Notary-state of Pennsylvania My comm. exp. April 30, 1988 HELEN p. KENYON, Plaintiff v. ARTHUR R. KENYON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 29 CIVIL 1987 IN DIVORCE AFFIDAVIT OF INTENTION TO RESUME PRIOR NAME COMMONWEALTH OF PENNSYLVANIA ) ) SS.: COUNTY OF CUMBERLAND ) HELEN P. KENYON, being duly sworn according to law, deposes and says that she is the Plaintiff in the above-captioned divorce action in which a final decree from the bonds of matrimony was entered and she hereby elects to resume her prior name of HELEN WHARTON PORTER, and, therefore, gives this written notice avowing said intention, in accordance with the provisions of the Act of April 2, 1980, P.L. 63, No. 26, ~702 (23 P.S. ~702). Sworn and subscribDd to before me,this ~ day of 1 7. f otary Public BERNICE M. LINSENBACH Notary-State of ?el~nsylvanla My cor, lm. exp. Aprit 30, 1988 HELEN P. KENYON To be known as HELEN WHARTON PORTER JUL 9 '87