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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF *' PENNA.
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CHRISTINE M. KRINER,
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PLAINTIFF
, ,,' ' ![ 95-709 CIVIL 95
N (I. "..,........,...................." 19
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VCI'S\lS
RONALD J. KRINER,
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DEFENDANT
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DECREE IN
DIVORCE
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AND NOW, ", ~ ,~l.., , ,l~.. .. , .. , ..' " 19,f.i.".., it is ordered and
CHRISTINE M. KRINER . ,
decreed that, " " , , , , ", , , , " , , " , ", " " ", , " , , , , " " " , " " plaintiff,
and"",.."""".. ,~C?~~,~J?, ~,., ,~~~~,r;~".."..,..,.."..,., defendant,
are divorced from the bonds of matrimony,
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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
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I I '/P.lthonotary
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CHRISTINE M. KRINER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
v,
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
RONALD J, KRINER,
Defendant
: NO. 95-709 CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, toge.her with the following information. to the court for entry of
a divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 330l(c) of the
Divorce Code.
2. Date and manner of service of the complaint: United States Mail, certified,
restricted delivery, return receipt requested, postage prepaid, February 23, 1995.
3. Date of execution of the affidavit of consent required by Section 3301(c) of the
Divorce Code: by the plaintiff, June 21, 1995; by the defendant, June 23, 1995.
4. Related claims pending: None.
Date~
J:- "'\
NICHOLAS J. CRAIG
1?~ft:~
ROBERT E. RAINS
Supervising Attorney
THOMAS L. PEELER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/240-5204
FEB , 0 \9r3" .
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
CHRISTINE M. KRINER,
Plaintiff
RONALD J. KRINER, JR.,
Defendant
: NO. 95- ?u'}
CIVIL TERM
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 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
Cumberland County Courthouse
Carlisle, PA 17013
717/240-6200
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: DIVORCE, CUSTODY
CHRISTINE M. KRINER,
Plaintiff
RONALD J. KRINER, JR.,
Defendant
: NO. 95- '10'1 CIVIL TERM
COMPLAINT
COUNT I.
DIVORCE UNDER 23 Pa,C,S. SECTION 3301Cc) and (d)
OF THE DIVORCE CODE
The plaintiff, by her attomeys, the Family Law Clinic, sets forth the following cause
of action:
1. Plaintiff is Christine M. Kriner, whose current residence in Snyder County is
not being revealed herein, but is known to her counsel.
2. Defendant is Ronald J. Kriner, Jr., who currently resides at 110 Cumberland
St., Duncannon, PA, 17020.
3. Plaintiff and defendant have moved out of Cumberland County on October I,
1994. Both parties agree, however, to venue in this county pursuant to Rule 1920.2 of the
Pennsylvania Rules of Civil Procedure. See consents attached as Exhibit A ahd B.
Plaintiff's address has been deleted from Exhibit A, but is known to her counsel.
4. Plaintiff and defendant were married on March 28, 1992, in Harrisburg,
Dauphin County, PA.
5. Plaintiff and defendant have lived separate and apart since May 30, 1993.
6. There have been no prior actions of divorce or for annulment between the
parties.
7. The marriage is irretrievably broken.
8. 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.
WHEREFORE, plaintiff requests the court 10 enter a decree in divorce dissolving the
marriage.
COUNT II.
CUSTODY
9. Plaintiff repeats and realleges paragraphs one through eight.
10. Plaintiff seeks custody of the following child:
Name
Present Residence
Age
Angelia M. Kriner
(address is not being revealed
but is known to counsel)
D.O.B.: 10-09-92
The child is presently in the custody of Christine M. Kriner whose current
residence is not being revealed herein, but is known to plaintiff's counsel.
During the past three years, the child has resided with the following persons
and at the following addresses:
Persons
Addresses
Dates
Christine and Ronald Kriner
N&G Apts.,
Old ]onestown Rd.
Linglestown, PA
10/92-11/92
Christine and Ronald Kriner, Apt., Old Jonestown Rd.
and Sue Fleck (roommate) Grantville, PA
12/92-01/93
Christine and Ronald Kriner, 200 Marlette Dr. 02/93-05/30/93
David and Wanda Mechanicsburg, PA
Weyandt (matemal
grandparents),
Brian Murray (uncle),
Lisa Weyandt (aunt),
Rick Weyandt (uncle),
and John Weyandt (uncle)
Christine Kriner, David and 200 Marlette Dr. 05/31/93-06/30/93
Wanda Weyandt, Brian Mechanicsburg, PA
Murray, Lisa Weyandt,
Rick Weyandt, and
John Weyandt
Christine Kriner 209 Marlette Dr. 07/01/93-06/94
Mechanicsburg, PA
Christine Kriner, Bonnie 4450 Panza Dr. 07/01/94-09/30/94
and John Jones Mechanicsburg, PA
(maternal great-
grandparents)
Christine Kriner, Darlene (address is not being 10/01/94-01/16/95
Gregory (roommate), revealed publicly but
and Ms. Gregory's is known to counsel)
son, Gene Herrold
(Christine's boyfriend)
Christine Kriner and (address is not being 01/17/95-present
Gene Herrold revealed publicly but
is known to counsel)
The mother of the child is Christine Kriner whose current residence in Snyder
County is not being revealed herein, but is known to her counsel.
She is married.
The father of the child is Ronald J. Kriner, Jr., currently residing at 110
Cumberland St., Duncannon, PA, 17020.
He is married.
11. The relationship of the plaintiff to the child is that of mother. The plaintiff
currently resides with the following persons:
Name Relationship
Gene Herrold plaintiff's boyfriend
Angelia M. Kriner daughter
12. The relationship of defendant to the child is that of father. The defendant
currently resides with the following persons:
Name Relationship
Amy (last name unknown) defendant's girlfriend
Amy's parents (names unknown) parents of defendant's girlfriend
13. Plaintiff has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody of the child in this or another court. .
Plaintiff has no infonnation of a custody proceeding concerning the child
pending in a court of this Commonwealth.
Plaintiff does not know of a person, not a party to the proceedings, who has
physical custody of the child or claims to have custody or visitation rights with respect to the
child.
14. The best interest and pennanent welfare of the child will be served by granting
the relief requested because:
a) Plaintiff has been primary caretaker of the child since birth;
b) Plaintiff provides the child with a home with adequate moral, emotional
and physical surroundings as required to meet the child's needs;
c) Plaintiff is willing to accept custody of the child;
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND: SS.
I verify that the statements made in this Divorce Complaint are true and correet to the
best of my personal knowledge and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsifieation to
authorities.
'"\ \'-" \ C\ ,-
Date~
~~" 1:1 h~, Q 12}.k()~(nOIL
CHRISTINE M. KRINER,
Plaintiff
PAMILY LAW CLINIC
A "Nice to thl community
by Itudln" from
Thl Dlcklnlon School olllw
Office: 45 North Pill SI.
Cerllall. PA 17013.2943
(717) 240.5204
(717) 243.2968
FIX: (717) 243.3639
February 7, 1995
Ms. Christine M. Kriner
(address deleted)
Dear Ms. Kriner:
On October 31, 1994, we spoke about your divorce action against your husband,
Ronald. At that time, you told me that you had moved out of Cumberland County on
October 1, 1994. Since neither you nor your spouse lives in Cumberland county, divorce
law requires that we obtain both parties' consent to proceed with the divorce.' If you still
wish to proceed with the divorce in Cumberland County, represented by the Family Law
Clinic, please sign the copy of this letter which is enclosed and retum it 10 us in the enclosed
stamped envelope. We are sending the same sort of letter to your husband for his signature.
Sincerely,
Kathryn Price
Certified Legal Intern
THE INFORMATION CONTAINED IN THIS LETTER IS TRUE AND CORRECT,
&}'7h~)
DATE
l 'I)(
U\!,0-1J~( /J/. /)1 ~n(1
CHRISTINE M. KRINER
Date~
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CHRISTINE M. KRINER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
: NO. 95- 7tJ'l CIVIL TERM
RONALD J, KRINER, JR.,
Defendant
PETITION TO PROCEED IN FORMA PAUPERIS
Christine M, Kriner, plaintiff in Ihe above titled action, respectfully re~uests this
Honorable Court to grant her leave pursuant to Pa.R.C.P. 1920.62 to proceed in fonna
pauperis to the extenl that she be relieved of all costs attendant to this action.
I
L~f4 1:=J3~U\
UNDA E. FISHER
Supervising Attorney
THOMAS L. PEELER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 170\3
717/243-2968
Date~
,
(Cll:.
CHRISTINE M. KRINER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
RONALD J. KRINER, JR.,
Defendant
: NO. 95- '/(]'i CIVIL TERM
t\TTORNEY'S AFFIDAVIT SUPPORTING PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
I, Kathryn Price, of the Family Law Clinic, attorney for the party petitioning to proceed
in fonna pauperis, certify that I believe petitioner is unable to pay the costs of instituting this
action and that I am providing free legal service to petitioner.
Plaintiff's Affidavit showing inability to pay the costs of litigation is attached hereto.
KATHRYN PRIC
Certified Legal Intern
L.-G l-l..1C! ~ _ 1/- ~
LINDA E. FISHER
Supervising Attorney
THOMAS L. PEELER
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
. "
CHRISTINE M. KRINER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
: NO. 95- 7u1 CIVIL TERM
\'.
RONALD J. KRINER, JR.,
Defendant
AFFIDAVIT SUPPORTING PETITION FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
TO THE HONORABLE JUDGES OF SAID COURT:
The Petitioner, Christine M. Kriner, residing at an undisclosed residence in Snyder
County, Pennsylvania that is known to her counsel, upon her oath deposes and says:
I. I am the named plaintiff in the above titled civil cause of action and the defendant is
Ronald J. Kriner, Jr.
2. This affidavit is made to infonn the court as to my status of indigence and to induce
the court to grant me leave to proceed in this cause as an indigent.
3. In making this affidavit, I am aware that perjury is a felony and thl\t the punishment
is a fine of not more than $3,000 or imprisonment for not more than seven years or both.
4. I do not have any money on my person, at home, or elsewhere which could be used
for the expenses of this proceeding.
5. I do not own real eSlate, personal property, or any other assets. I am not owed any
amounts of money by any person.
6. My husband, Ronald J. Kriner, Jr., presently resides at 110 Cumberland St.,
Duncannon, PA, 17020. He is 20 years old (D.O.B.: 05-19-74).
(a) I last lived with my husband in May, 1993.
(b) My husband works as a construction worker.
. .. .
. "
(c) I do not have jnfonnation or knowledge as to whether my husband has any
money, owns real estate, or has any other personal property or assets.
(d) My husband owns a car but I do not know its make, purchase price, or if any
money is owed.
(e) I have brought action for Child Support payments. The Child Support
payments are $40.oo/week ($160.00/month) and my Do"mestic Relations
number is 21705. My husband's last payment was mid-November, 1994.
Spousal Support was denied.
7. I have one child, Angelia M. Kriner, who was born on October 9, 1992, and resides
with my boyfriend, Gene Herrold, and myself.
8. I am presently unemployed.
9, My social security number is known to my counsel. It has not been revealed
publicly because I do not want my husband to obtain it. Should the court so desire, my counsel
can reveal the number under a protective order.
10, I have the following monthly income:
(a) Child Support:
$160.oo/month ($40.oo/week)
(b) Cash Assistance:
$152.50
(c) Medical Assistance:
Medical Card
(d) Food Stamps:
$207.00
(e) TOTAL INCOME:
$519.50 (and a Medical Card)
11. My monthly expenses are as follows:
(a) Rent:
(b) Phone bill:
$120.00 (includes local phone bill)
$ 50.00 (Long Distanee only; I owe approximately
$500.00 in back bills)
(c) Food:
$ 35.00
$200.00
(c) Electric bill:
. " , . " .
(d) Cigarettes: $ 80.00
(e) Car Insurance: $ 58.00 ($7oo.oo/year)
(0 TOTAL EXPENSES: $543.00
12, My husband and I have not maintained a checking account throughout our marriage.
13. I own a 1981 Chrysler Le Baron automobile. I paid $100.00 for the car and nothing
is owed.
14. I understand that I have a continuing obligation to infonn the court of improvement
in my financial circumstances which would pennit me to pay the costs incurred herein.
15. 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.
WHEREFORE, petitioner prays that this Honorable Court grant petitioner leave to
proceed in fonna pauperis in the above titled action without fee or cost to the petitioner.
Date~ \ 1-' Or)
. ,- .
. " ,
CHRISTINE M. KRINER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
RONALDJ. KRINER,
Defendant
: NO. 95-709
CIVIL TERM
CERTIFICATE OF SERVICE
I, Kathryn Price, Certified Legal Intern, Family Law Clinic, hereby certify that I have
served a true and correct copy of said Divorce Complaint on Ronald J. Kriner, Jr., residing at
110 Cumberland St" Duncannon, PA, 17020, by depositing a copy of the same in the United
States mail, certified, restricted delivery, return receipt requested, postage prepaid, this 23rd day
of February, 1995.
II '
I"-D,-+k't l'}l\
Kathryn Price !"
Certified Legai Intern
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. .....
- .- .
CHRISTINE M, KRINER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
: NO. 95-709 CIVIL TERM
v.
RONALD J. KRINER,
Defendant
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
February 9, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the dale of filing the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that if a claim for alimony, alimony pendente lite, marital property or
.
counsel fees or expenses has not been filed with the Court before the entry of a final decree
in divorce, the right to claim any of them will be lost.
5. I understand that I may request marriage counseling and I hereby waive any right
to marriage counseling which is afforded to me under the law.
I verify that the statements made in this affidavit are true and correct. I understand
that false stalements herein are made subject 10 the penalties of 18 Pa.C.S. ~ 4904, relating
to unsworn falsification to authorities.
Date~ ~3-'r
<~ A'l~
RONALD J INER
.. .~...
. .. .
CHRISTINE M. KRINER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
: NO. 95-709 CIVIL TERM
v.
RONALD J. KRINER,
Defendant
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on
February 9, 1995.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
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 if a claim for alimony, alimony pendente lite, marital property or
counsel fees or expenses has not been filed with the Court before the entry of a final decree
in divorce, the right to claim any of them will be lost.
5. I understand that I may request marriage counseling and I hereby waive any right
to marriage counseling which is afforded to me under the law.
I verify that the statements made in this affidavit are true and correct. I understand
that false statemenls herein are made subject to the penalties of 18 Pa.C.S. ~ 4904, relating
to unsworn falsification 10 authorities.
Dat~
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CHRISTINE M. KRINER
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CHRISTINE M. KRINER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE, CUSTODY
: NO. 95-709 CIVIL TERM
v.
RONALD J. KRINER,
Defendant
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Plaintiff in the above matter, having been granted a Final
Decree in divorce from the bonds of matrimony on the 14th day of July, 1995, hereby elects to
retake and hereafter use her previous name of Christine M. Kriner.
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CHRISTINE M. KRINER
Wishes To Be Known As:
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CHRISTINE . WEY DT
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND SS.
On the ?- { ;rrd'ay of ~ ' 1995, before me, a Notary Public, personally
appeared Christine M. Kriner, known to me to be the person whose name is subscribed to the
within document, and acknowledged that she executed the foregoing for the purpose therein
contained.
IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal.
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NOTARY PUBLIC
NOTARIAL seAL
~ .. ..ltNCMll0H, """ory Public
eor1lale cumberland County
Mr~Esp1r..*;.li/1lIlIr'.1998
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