Loading...
HomeMy WebLinkAbout02-4973 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Kimberly Ann Keebaugh Plaintiff VS. Daren Lee Keebaugh Defendant No. Civil Action - Law 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 in divorce or annulment may be 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 the custody or visitation rights of your children. When the ground for 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, 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717)-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Kimberly Ann Keebaugh, Plaintiff VS, Daren Lee Keebaugh, Defendant : No. 0,~. - ~73 : : Civil Action - Law : In Divorce COMPLAINT UNDER SECT[ON 3301 OF THE DIVORCE CODE Plaintiff is Kimberly Ann Keebaugh, who currently resides at 219 SME, Shippensburg, Cumberland County, Pennsylvania, since March 15, 1995. Defendant is Daren Lee Keebaugh, who currently resides at 19 Corporation Street, Newville, Cumberland County, Pennsylvania, since June 2002. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this complaint· 4. The Plaintiff and Defendant were married on July 19, 1999, in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted. Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 ! veri~ that the statements made in this Complaint are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date:~~ ~ Idmberly~nn- Keebaugh IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Kimberly Ann Keebaugh, Plaintiff VS. Daren Lee Keebaugh, Defendant : Civil Action - Law : · In Divorce : AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Daren Lee Keebaugh, of 19 Corporation Street, Newville, Pennsylvania, 17241, certified mail, return receipt requested on October 18, 2002 and was accepted on delivery by Daren Lee Keebaugh on October 21, 2002 as shown by the attached receipt. H. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 Sworn to and subscribed this o?4~day of October 2002. Notary Public My Commission Expires: · Complete items 1,2, and 3. Also comptete item 4 if Restricted Delivery is de<-~ired · print your name and address on the reverse so that we can return the c&rd to you. · Attach this card to the back of the mailpiese. A. Signature B. r-I Agent Date o! Detivery [3 Yes is delivery address different or on the front if space permits. D. i~l~er delivery address betoW: r'JNo I Art c,e Addressed to; - -- T~Ic~ · \tc~.~..~, = v,, ~,~ Fi Registered ~.~ ~_~u~, F~',;;;red ~e~ ~ c.o.~ ~- 7001 2510 0001 6144 7016 2. ~icle Number 102595-02-M-1~ ~ns~r from se~ice Jabel) D(~mestic Return Receipt ~S Form 3811, August 2001 First-C/ass Mail POStage & Fees Pal ~ USPS - Permit No. G-lO ° Sender: Please print your name, address, and ZIP+4 in this box ° i'"lll'"l"hi'hl,h,,i,,,ilt,,I,,,,lll,h,li,,,,,ll,,ll,,i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY-PENNSYLVANIA Kimberly Ann Keebaugh · No. 02-4973 Plaintiff · Civil Action - Law VS. Daren Lee Keebaugh ' Defendant · In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 14,2002. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~en ~,~e K~ebaugh Defendai~-~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Kimberly Ann Keebaugh Plaintiff VS. Daren Lee Keebaugh Defendant · No. 02-4973 : · Civil Action - Law .. : · In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 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. Date:~/~ 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. Section 4904 relating to unsworn falsification, to authorities. ~ea~dLa nt~ebaugh- ~ - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY-PENNSYLVANIA Kimberly Ann Keebaugh : No. 02-4973 Plaintiff : : Civil Action - Law VS, : : Daren Lee Keebaugh : Defendant : In Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 14,2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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 understand that false statements herein are made subject to the penalties of !8 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Y '~ ~eebaugt~/ ,~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Kimberly Ann Keebaugh Plaintiff VS. Daren Lee Keebaugh Defendant · No. 02-4973 · Civil Action -- Law · In Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of properb/, lawyer's fees or expenses if I do not claim them before a: divorce is granted· 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 alter 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. Section 4904 relating to unsworn falsification to authorities. i~m berly ~A~n- Keeba ugl~ Plaintiff IN THE COURT OF COMMON pLEAs OF CUMBERLAND COUNTY-PENNSYLVANiA Kimberly Ann Keebaugh Plaintiff VS. Daren Lee Keebaugh Defendant · No. 02-4973 : · Civil Action - Law .. .. · 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; Ground for divorce; irretrievable breakdown under 330:[(c) of the Divorce Code. Date and manner of service of the complaint: Service was made by Certified Mail Return Receipt Requested on October ;[8, 2002, and was accepted October 2:[, 2002. An affidavit of service was filed on or about October 28, 2002. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff, February 4, 2003 filed February :[0, 2003; by Defendant February 3, 2003 filed February 4, 2003· 4. Related claims pending: None. Plaintiff signed a waiver of notice on February 4, 2003 which was filed with the Prothonotary on February 10, 2003; Defendant signed a waiver of Notice on February 3, 2003 which was filed with the Prothonotary on February 4, 2003. · Anthony Adams, I~squire'~- ~-) Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, Pa. ~7257 IN Kimberly THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF ~ PENNA. Ann Keebaugh NO. - 02 -~973 VERSUS lee ~b~,]gh PLEAS DECREE IN DIVORCE ^NO NOW, DECREED THAT~ AND ' ~)J~3--, iT iS ORDEREd AND , PLAINTIFF, ~ , DEFENDANT, AREDIVORCED 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; PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY-PENNSYLVANIA Kimberly Ann Keebaugh Plaintiff VS. Daren Lee Keebaugh Defendant · No. 02-4973 · Civil Action - Law · In Divorce NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce on March 7, 2003, hereby elects to resume the prior surname of Strayer, and gives this written notice pursuant to the provisions of 54 P.S. section 704. DATE: K)mberly A~ Keeb~ug K~mberly Ab~n Strayer Commonwealth of Pennsylvania: :SS County of Cumberland ' ~-¼ AND NOW, this/~ day of April, 2003, before me, a notary public, personally appeared Kimberly Ann Keebaugh and acknowledged the foregoing written notice of intent to resume her prior name to be her act and deed and to that end that it may be recorded as such. Notary Public· Notarial Seal H. Anthony Adams, Notary Public 'Shiplmnsburg Boro, Cumberland County My Commission Expires May 15, 2006 M~qIID~', Pertnsv~eni8 A~soCiation ot Notaries