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HomeMy WebLinkAbout00-00333 .-1 ',_ ',1 ,'--'J,-.' ." '~"'~A ::i:'+::!~):C;::,'-::~:C~~:):C~JX'~>>X>3t(::,~>>XJ~::c.~::~~::*;lo-~~::.-:~~:,):cf~'X+>~;:-X+::~~:}~(::,~::+::~::;:~~>>X:::~:C~~:K.};;:':::!:cf;:::~~>>:::~~;y*~r;:~::c.*3~::-C~~~C;-H,~+::~H~:::+x':~~:c~t:~~:::.:}~;~:;~!::e{%!:::.:::*~~1 ~ ~ ~ I ~~?, ~.'~ ,~ i ''''. ~~~ ~ ~";~ ~ ~i ~ ~.~ ~ ~.~ * ~.s ~ ~~~ ~ ~'S ~ i ~ S N ~ )~ ~ ~.~ i ~.~ ~.~ I ~ ~.; ~ ~.~ ~ ;.:; J:li ~-', ~ ~.~ ~~~ ~ ~ :~~::.x :::.::+::<::.:'+::',. '.::':::.::.':: :::~::.::<:::.3::':. .::-::.::< ::'.::.::~.:: :::.::.::< X+::.;' r I ~.;~ ~ IN THE COURT OF COMMON PLEAS ~ OF CUMBERLAND COUNTY STATE OF PENNA. ~,,;i ~ .. .J()1\.~r-l];;: R~.. _I<~c.I<!., n _ m n.. n _ 0 00..... PLAINTIFF N O.2,~,~o~o-::~}3.n' qYJ::L.nn I~ Versus nm..J1:I:SON L. nI<J;:<::I<L..mnn.ommm DEFENDANT ~ ~.; ~ i I ~ ~.~ ~.~ ~ ", a !l~~ tJ ~ ~.~ i ~.~ ~.~ , ~.i ~ DECREE IN D I V 0 R C E ~1/:~r4.#J. AND NOW, ...... ~ .~..I?......, n .?9.0.Q, it is ordered and decreed that.. . . 0 .. . . . .. . .. . . . . . .~()~~.~~. ~... .~~~I<.. .. . . .. . . .. plaintiff, and.......... 0................... .J!".s.~f!. ~'..~~~I<..........., 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; THE PARTIES MARRIAGESETTLEM~NT AGREEMENT, DATED MAY 4, 2000 ."". ,.......,...." ,.. ,..,.,'.,........, ............ ....,...,........,. " . .1.Ei . J!"I.C;Q~!'P.R,~TED. ,fJERE-IN . AS. .A. FI.NAL. ORDER. .OF. COURT... . . . . . . , . . . . . . . By Th ~{ ~ ~ ~ ~ i . L~~~~~~~~~~--------- Attest: an ---... Prothonotary ~~~ ~ a ll.~ ~~~ ~ ~ ~.~ ~ ~ ".", ~ ll." ~~~ ~ s ~ ~ ~~~ I ~ ~.~ ~ ~ ~.~ , ~', :"'s ~ n f..~ ~ N I tc, ~.~ ~ ,~':. ~.'~ ~ ,'" ~ ~.~ i "'.~ ~ "'.~ ~'S ~ :".; i ~.~ ~ ~ ~.~ J. ~ ~.~ ;.~~ ~ ~ 'l ~ t" . , ". ,'~ ,'. ~;, ..' '. '"' , ' . ~.,/.5-:C2:7 (}wi %~ 7fT 4~~ &. /<s-Ot:T ~ pif~ ~ 4- ~ \ I" ' -" -., - ~ ",."" ~~ ~ -, ~ - . - . , ~" <,.,-- MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT, made this lf71J. day of !h Aj , 2000, by and between Jason L. Keck, hereinafter called Husband, and Joanne R. Keck, hereinafter called Wife; WITNESSETH: WHEREAS, Husband and Wife were lawfully married on March 17, 1995 in Cumberland County, Pennsylvania; and WHEREAS, differences have arisen between Husband and Wife in consequence of which they have determined to live separate and apart from each other and have consented to a mutual consent divorce; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations, including the settling of their property rights and other rights and obligations growing out of their marriage in accordance with the provisions of the Divorce Code of Pennsylvania. NOW, THEREFORE, the parties, intending to be legally bound hereby, agree as follows: 1. Separation, It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place as he or she may from time to time choose or deem fit. The foregoing provision shall not be taken as admission on the part of either party of the lawfulness or unlawfulness of the causes leading to them living apart. Each party shall be free from interference, authority and control, direct or indirect, by the other as fully as if he or 1 iI she were single and unmarried. Neither shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her. 2. Division of Prooertv. The parties will divide between them, the personal effects, tools, equipment, household furniture and furnishings, and other articles of personal property which have heretofore been used by them, individually or in common. Wife shall have the items in the parties residence identified on Exhibit A and she shall remove them when she moves from the parties residence. Any items remaining after she moves from the residence shall be deemed Husband's property. Wife shall retain the 1996 Pontiac Grand Prix and Husband shall retain the 1999 Ford pick up. The parties agree to co-operate in transferring title and ownership of the vehicles. Each party shall be responsible for the financing on their vehicle and agrees to indemnify and hold the other party harmless on any claims from the lender. The 1991 Skyline manufactured home owned by the parties and located in Newville, Pennsylvania shall become the sole and separate property of Husband. Husband shall assume and be fully responsible for the real estate taxes and the mortgage on the property owed to Cornerstone. Husband will refinance the existing Cornerstone obligation in his name alone at the earliest possible time, so that Wife is no longer obligated to the lender. Wife agrees to cooperate in transferring title to the home to Husband on or after the execution of this Agreement and upon her being released from the loan obligation to Cornerstone. 2 II Each party shall retain his/her pension/retirement accounts and they agree that they will each sign any documentation reasonably requested to release and extinguish any interest that they may have in the other's accounts(s), 3. Child Custodv and Support, The parties shall share legal and physical custody of their daughter, Kady Renee Keck, born October 26, 1996. The Father shall have Kady on all days that he is off work and the Mother shall have her on all other days. The parties agree that any child care will be provided by Becky McCloskey and they will share equally in the expense of child care. In the event either party is dissatisfied with the custody arrangement the matter shall be submitted to the Court for resolution and this arrangement shall continue until such time as a Court Order modifies it. 4. Alimonv and Spousal Support. The parties agree that they waive any present or future claim for alimony or spousal support 5. Debts. Except for the debts and obligations created hereunder, each party agrees to pay and hereby agrees to hold the other harmless from any and all personal debts and obligations incurred by him or her subsequent to the date of separation which occurred in December, 1999. If any claim, action or proceeding is hereafter brought seeking to hold the other party liable on account of such debts or obligations, each party will at his or her sole expense defend the other party against any such claim, action or proceedings, whether or not well-founded, and indemnify the other party against any loss or liability resulting therefrom, 3 II 'j Wife agrees that she will assume the joint credit card debt owed to First USA in the approximate sum of $6,700. She agrees that she will see that Husband is released from liability on this obligation at the earliest possible time. 6. Equitable Propertv. This Agreement constitutes an equitable division of the parties' marital property. The parties have determined that the division of this property conforms with regard to the rights of each party. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effectuated without the introduction of outside funds or other property not constituting the matrimonial estate. Each party hereby acknowledges that this Agreement adequately provides for his or her needs and is in his or her best interest, and that the agreement is not the result of any fraud or undue influence exercised by either party upon the other or by any other person or persons upon either party. Both parties hereby waive the following procedural rights: A. The right to obtain an inventory and appraisement of all marital and separate property as defined by the Pennsylvania Divorce Code. B. The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code. C. The right to have the court determine which property is marital and which in non-marital, and equitably distributable between the parties that property which the court determines to be marital. 4 II D. The right to have the court decide any other rights, remedies, privileges, or obligations covered by this Agreement, including but not limited to possible claims for divorce, spousal support, alimony, alimony pendente lite (temporary alimony), and counsel fees, costs and expenses. 7. Mutual Release. Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors, administrators or assigns, does remise, release, quit-claim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits at law or in equity, of whatsoever kind or nature, for or because of any matter or thing done, admitted, or suffered to be done by said other party prior to and including the date hereof; further, the parties hereto have been advised by their legal representatives, respectively, of all their rights under the Pennsylvania Divorce Code, and such rights as are not specifically incorporated herein are hereby expressly waived. Notwithstanding the foregoing language of this paragraph, this release shall in no way exonerate or discharge either party hereto from the obligations and promises made and imposed by reason of this Agreement and shall in no way affect any cause of action in absolute divorce which either party may have against the other. 8. Release of All Claims. Each party, except as otherwise provided for in this Agreement, releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been incurred, or may be incurred, relating to or 5 II arising from the marriage between the parties, including waiving any claim to their respective pensions or retirement accounts. However, neither party is relieved or discharged from any obligations under this Agreement or under any instrument or document executed pursuant to this Agreement. 9. Breach. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach, and seek any other remedy allowed in law or equity. The party breaching this contract shall be responsible for the payment of legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. Waiver by one party of any breach of this Agreement by the other party shall not be deemed a waiver of any subsequent, similar breach or other breaches. 10. Full Disclosure. Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other of all assets of any nature whatsoever in which such party has an interest, of the source and amount of the income of such party of every type whatsoever and all other facts relating to the subject matter of this Agreement. 11. Divorce. This Agreement shall not be construed to affect or bar the right of either Husband or Wife to a true and absolute divorce on legal and truthful grounds as they now exist or may hereafter arise. 12. Representation of Parties by Counsel. Each party has had the opportunity to have legal counsel to represent each of them in the negotiation and preparation of this Agreement 6 I I: II and has either been so represented or has voluntarily chosen not to be represented. Each party has carefully read this Agreement and is completely aware, not only of its contents, but also of its legal effect. 13. Additional Instruments. Each of the parties shall on demand or within a reasonable ji l' I ! I,ll I I, I I period thereafter, execute and deliver any and all other documents and do or cause to be done any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party fails on demand to comply with the provision, that party shall pay to the other all attorneys' fees, costs and other expenses reasonably incurred as a result of such failure, 14. Modification and Waiver, Modification or waiver of any provision of this Agreement 1 I" II :1 1'1 I: I I shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 15. Descriotive Headinas. The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties, 16, SLlccessors and Assians. This Agreement, except as otherwise expressly provided herein, shall be binding upon and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assignees and successors in interest to the parties, 7 II ~ f I I I" 17. Governina Law, This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. , I I, 18. Order of Court. With the approval of any court of competent jurisdiction in which any divorce proceeding may now be pending or which may hereafter be instituted, this I I I ~,; Agreement shall be incorporated in any decree of absolute divorce which may be passed by 1,- .:: said court. In the event the court shall fail or decline to incorporate this agreement or any , I: provisions thereof in said decree, then and in that event the parties, for themselves and their r-- , f: t, , i-' respective heirs, personal representatives and assigns, agree that they will nevertheless abide by and carry out all of the provisions thereof. It is further agreed that regardless of whether said agreement or any part thereof is f j: l " I: ii" incorporated in any such decree, the same shall not be merged in said decree, but said agreement and all the terms thereof shall continue to be binding upon the parties and their respective heirs, personal representatives and assigns. IN WITNESS WHEREOF, intending to be legally bound hereby, the parties hereto have hereunto set their hands and seals the day and year first above written. (SEAL) JASON l. KECK ~~~.k-ec^- (SEAL) a-JOANNE R. KECK 8 II , "', 'i i !,I ':1 . - , :,1 i..i I:'! ;.-j ;;! f,] ,,' !i i1 ~I n );;1 I:,i !I II ~1 I' " [I r;i ~1 SS. Notarial Seal . Larry L. Morrison, NO,tnry PU?\!C , Carlisle Bora, GUl1?t)!?nB.n~ COUIVY n"J' My Commission Expl~:S JUlIe 1 0, ~O~;'~ ':' ,Member, Pennsylvania As~6ciationo( NO f' COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AND NOW, this 'fn: day of Infly , 2000: before me, lhelJridersigned officer, personally appeared Jason L. Keck, known (0 me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ctd cY 1h@1, , Notary Public :>! , " COMMONWEALTH OF PENNSYLVANIA Notarial Seal Larry L Morrison, Notary Public Carllsie Bora, Cumberland County SS. My Commission Expires June 10, 2002 Member, Pennsylvania Association at N0tarte5 f:! ., COUNTY OF CUMBERLAND i.~ I , Ii r; ", 1'1 " AND NOW, this 4ft'day of May ,2000, before me, the undersigned officer, personally appeared Joanne R. Keck, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed same for the purposes therein contained. " ri , I: I:! " I. ., ;1 ij ~ I , IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public Notarial Seal Larry L Morrison, Notary Public Carlisle Boro, CumberIDnd County My Commission Expires June 10, 2002 'Member, Pennsylvania ASSClciation of Notaries 9 II ~IliiIIlIl"" -, ~^ -= ^'~.-- ". =",,-. .......,.. , ~ ' - "",,> ~I " ,,~ ~' () 0 0 C \..J " ~ , ...~ ,.;;."~. ;; '.r~:D vG) nlj'T' 0~ Z::t~ e~ S'~~ N -<~-: r;:C::'< -0 -,~' '-I --~,- ~Tl )..::; ~- ~-;(') ~7(:;' -.,... ~8 r;-? Om 2~ :A ~ =< \0 ~ JOANNE R. KECK, Plaintiff i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW JASON L. KECK, Defendant NO. 2000-333 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: 'I :1 I I I 1. Ground for divorce: irretrievable breakdown under Section 3301 (C) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant signed an Acceptance of Service on January 20, 2000. 3. (complete either paragraph (a) or (b).) :1 I :, 'I :j :1 '.1. 1 I , , I , A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff on May 4, 2000; and Defendant on May 4, 2000. B. (1) date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: (2) date of service of the Plaintiff's Affidavit upon the Defendant: N/A 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301 (d)(1 )(i) of the Divorce Code: None served as the parties signed the Waiver of Notice. (Defendant on May 4, 2000 and Plaintiff on May 4, 2000). Respectfully submitted, 'r-t<1)~AAV- Robert L. O'Brien, Esquire II " , II ~, -- ~ ,,~~ '""" ~. ." liiII .. (') c:> 0 c:: 0 .." < L- .-1 -OW c: ~i:JJ rnrn z Z:L' ,-~)m zs;: N :c,y (j) "-'.~ ~~(:) -< .' ~C::' -0 :]; :t:\ yr" ~,' !=~(~ ...." 20 ~<:'.rn >c -:) -I Z 0 ?o ~ c:> -< JOANNE R. KECK Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO.2000- .3.33 CIVIL : IN DIVORCE vs. JASON L. KECK 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. 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 Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone: (717) 249-3166 Ii JOANNE R. KECK Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO.2000- 333 CIVIL : IN DIVORCE vs. JASON L. KECK Defendant COMPLAINT UNDER SECTIONS 3301 (C) AND 3301 (0) OF THE DIVORCE CODE 1. Plaintiff is Joanne R. Keck, an adult individual who currently resides at 169 Cedar Lane, Carlisle, Pennsylvania 17013. 2. Defendant is Jason L. Keck, an adult individual who currently resides 133 CME, Newville, Pennsylvania 17241. 3. 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 March 17, 1995 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6, The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the court require the parties to participate in counseling, I II II 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER By ~ 2 il~ A A...V-. Robert L. O'Brien, Esquire Attorney for Plaintiff 1.0. # 28351 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 II I verify 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. ~ 4904, relating to unsworn falsification to authorities. ~~~ JOANNE R. KECK Date: \-11-00 \0' '.. 0 n ~ > Vi ~ uo '" ~ '" ~ 0 ?= '" "i rii :r ~ s: Z :r " Z > ::0 ~ V> Z - -< 0 Cl ~ ~ R < < II> m ~ > '" Z ~ tJl s: ~ Cl ';:j = 0 m '" W -; !::; ::0 , . . ~~ P~~~2 ..lL ;" tf :tI:;R ~ -ij- V \ 2fT. 0' ZF' ~ P. ~ ~~; lh :t: l,u ~8 ~ \..,J:: p ~ ' o ::<; .():) ., ---- f7> c..... . , o -''1 "":j-l.) .'elfTl ~':-; (:J ~~~'f (~; 9~ t-srn c:, ~. ::0 -< .::J ::~ '-"'j JOANNE R. KECK, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-333 CIVIL TERM 3 g ~ JASON L. KECK, u ~ ~;J Defendant IN DIVORCE g;Jy) -< i1if!1 zr Iqm (f)~' (,X) :-:lJI,~, -<:;...:. () C;::C:; v .::::i-!{, :i> C' -,- .J.; +! AFFIDAVIT OF CONSENT, ACCEPTANCE OF ~g ~ ,~~ SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUES$N'ffl.Y ~ OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301 (C) of the Divorce Code was filed on January 18, 2000. 2. Defendant acknowledged receipt and accepted service of the Complaint on 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling, I do not request that the court require counseling. 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. Date: 5-4-00 ~kJ4,/~ . OANNE R. KECK ";"i- 0 0 ~ C 0 s: ::ll: .,-1 -OeD :J;>' :-:!:.." rnrT', --'" n"r- z:X~ I :i"~ ZC ~:2~ co 6 ..--i: , co -0 ~, I ~ ,'-<:D :p:(--' :J{ '20 z," -m ~~ t.:t ~ ~ ::',0.) ~ (,) - -,., " ~? ~~ - .~< , - , JOANNE R. KECK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2000-333 CIVIL TERM v. JASON L. KECK, Defendant IN DIVORCE AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301 (C) of the Divorce Code was filed on January 18, 2000. 2. Defendant acknowledged receipt and accepted service of the Complaint on 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice, 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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, ~_u_() cJ Date: ,L ( .2 '-"-, -',"-""r- .,,~ n 0 0 c c;> .'1 s:: :x '~j -0(D ,. ri'iFJ rnfT! -< 2:,) ! -!'",m 2C vi)'l;::1 G0",t-" Q:) ," 1- -<2, ':?<;fl "\ ""' \<0 -0 .r , 6:0 ):"0 ::t;: 'M 26 z,:_ C:? 0' )>c j;! ~ w ::Q r" 1~ JOANNE R. KECK Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs, JASON L. KECK Defendant : CIVIL ACTION - LAW : NO.2000-333 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this 20th day of January, 2000, I, Jason L. Keck, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa. R. C, P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. /~/' ~ /' Jason L. Keck !; I' ~ , J ilIilllil --~ ;il (") 0 0 C 0 " $: '- u'; "'Om c ~::~F'Q IT1rn :z :z: '-- "r:f11 :z:C N :;~y WL:': ~E~ V ~~~ 2;:0 ~ ~C' 1;'0' 5>"" c 0;;; 2; <.J1 :a =< ~o -< I .' JOANNE R. KECK Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Vs. Defendant : CIVIL ACTION - LAW : NO. 2000-S~~ CIVIL TERM : IN CUSTODY JASON L. KECK ORDER OF COURT AND NOW THlsli!1ay of January, 2000, upon review of the attached Petition for Special Relief, this Court sets a hearing in this matter for 7J.1LIU~ 'I the )tj -t;A day of t,Jft I\I.~" . ..I, 2000, at ?: ~() ~in Courtroom # -5 , I ~~ of the Cumberland County Courthouse, Carlisle, Pennsylvania. ~~ J. j-//OCJ I?I!s -~'- -- ~--,',. --,-'-~, " . JOANNE R. KECK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000- .333 CIVIL TERM Vs. JASON L. KECK Defendant IN CUSTODY PETITION FOR SPECIAL RELIEF 1) Petitioner is Joanne R. Keck, Plaintiff in the above-captioned action, 2) Respondent is Jason L. Keck, Defendant in the above-captioned action. 3) Petitioner incorporates the pleadings as set forth in her Complaint for Custody herein, 4) Petitioner has been denied reasonable access to and custody of her child and requests that the Court set an emergency hearing so as to set the parties' rights herein in regard to custody of Kady Renee Keck, age 3 years, born 10/26/96, WHEREFORE, Petitioner respectfully requests that Your Honorable Court set an emergency hearing so as to set the parties' rights herein in regard to custody of the parties' child, Kady Renee Keck, Respectfully submitted, Date:~ -- t?n6.. ~ Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 , , .' , I verify that the statements made in the foregoing Petition for Special Relief 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. ~"~~.YeA~ OANNE R. KECK DATE: '1''7100 fl II. r" JOANNE R. KECK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000- CIVIL TERM IN CUSTODY Plaintiff Vs, JASON L. KECK II Ii II II I \ Ii Defendant COMPLAINT FOR CUSTODY 1. Plaintiff is Joanne R. Keck, an adult individual, currently residing at 169 Cedar Lane, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Jason L. Keck, an adult individual, currently residing at 133 CME, Newville, Cumberland County, Pennsylvania, 17241. Ii I 3. Plaintiff seeks custody of the following child: Kady Renee Keck, age 3 years, born 10/26/96. The child was not born out of wedlock. ii II " Ii I I I the following persons at the following addresses: , The child is presently in the custody of Defendant, who resides at 133 CME, Newville, Cumberland County, Pennsylvania, During the past five years, or since the child's birth, she has resided with (a) from birth to December 29,1999 with the parties at 133 CME, Newville, PA. (b) from December 29, 1999 to present with each party on an alternating basis. The natural mother of the child is Joanne R. Keck. ii .- ~ II. 1"-' She is married. The natural father of the child is Jason L. Keck. I I II 'I The Plaintiff currently resides with I He is married. 4. The relationship of the Plaintiff to the child is that of natural mother. 5. The relationship of the Defendant to child is that of natural father. I, " 'I II Ii II ,i 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the children in this or in any other Court. Plaintiff has no information 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The mother has been the primary caretaker of the child since her birth and is capable of providing the care a child needs, (b) The mother needs to have a Court Order as father has threatened that he will take custody of Kady from the mother and this concerns her greatly. 8. 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 ii t.- II '.' I: - ' r' I II, I parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this II action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None WHEREFORE, Plaintiff requests your Honorable Court to: Ii II I i I I A) grant custody of the child to the plaintiff; B) set an emergency hearing in order to set the parties rights until such time as there can be a full hearing in this matter; C) grant such other relief as is just and in the best interest of the child including the award of attorney's fees against the father. Respectfully submitted, II II I: II Ii Date:~ ~a~~ Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 ~ , -- I verify that the statements made in the foregoing Complaint for Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. I ~ Il-e ,f.-- ANNE R. KECK' , DATE: ~ j! ii I Ii II 11 il :i I, 1-' ~~l)OZ' 9 T NVr .,.. ,~ " .." ;iio ~ 2 $: ::!<ev ~n--~ ~.-' ~f~! C6,,:::~ ;S'~ $b <::<J ;;:;:0 c: .c :< C:> (::) <3 -on "---I' s- ",,~\10 ~ ;--.>--l,.~S ,- ,~9? (0~~~ 5;.' ::n - Co -0 :::: - .. :.> .>oJ -< , 0 " ci )- u; ~ '" ::<l - v; is '" , F " ?: 2 -i J: g s: s: '" z ::<l '" '" z (=i -< 0 ~ ~ i"i < ;;; II" )- '" Ci z ~ C/l :;; -i ("'> " " ~ = 0 ~ '" , w i;; ::<l , , ", "" ,I ,;J >' -, JOANNE R. KECK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JASON L. KECK, Defendant 2000-333 CIVIL TERM IN RE: CASE CONTINUED ORDER OF COURT AND NOW, this 20th day of January, 2000, by agreement of the parties, hearing on Plaintiff's Petition for Special Relief is continued generally, to be rescheduled at the request of either party. This matter is to be referred to conciliation. By the Court, ~ Edward E. Guido, J. ~JirWJJ / - :z L/ -00 p,j{3 Robert L. O'Brien, Esquire For the Plaintiff Thomas S. Diehl, Esquire For the Defendant It ',- - ~~.....,,~ --~ ''--'''''' 1;i1N"jt\\'\SNN:Jd }..l.NnC() Oi<\1lH?'2V\in8 l'jt; :1:: ~{d \? ",,'< 00 1 ",,'J'I " f , \:. ~ ." }\B"l!r'\,'''' " r" \ 1',\ )'I--j' \. ,,-~.-~ 1 ..11 \ . ,~v,-,,,~ j0\j~.o"--(B-id :,Ci ~..~-~- i~ -:J rJ ",i'-',.., JOANNE R. KEGK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO, 2000- 33.3 CIVIL TERM Vs. JASON L. KECK Defendant IN CUSTODY ORDER OF COURT AND NOW THIS & ~ay of --h.V"\IIQ. rl.4 ,2000, upon consideration of the attached complaint, it i hereby directed that th81parties and their respective counsel appear before i , the conciliator, at b. Co. on the ~ay 0 , 2000 at~O A.M .M., for a Pre;Hearing Custody Conference. At such conference, an effort will be ade 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. BY THE COURT, BY ~;f '^~ R,; Custody Conciliator I ,y 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 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF 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 Ii :~ 13/.a7 /3i-;;7.(.! / ::.J1-t9t:7 ell ;:or, ~'-' _r-..... _ I "--~lN 1I-"'-'if""C ur lin.!f:,- t'-'lr'"'::,,' tll,JL . 'Ii.." .".,,'..1 f !-!O:\I,rlT/\R,'V .~~' If \j I 00 JAN 3! Pl1 ". I ,., I '.I.:.J~ CUf'I-;':;:e;'", 'ILJ'-I!U.J;':I" ,--.-... ""'r- . \. '-u I J :; ./ nv rc:NNs"/l'\'t,^/7'A"U!\Ji f I, u~!. td~~~4 O~ ~~~dfI: ~~~ y~p ~, r"~~ '1 ,~;, , '" " , JOANNE R. KECK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000- 333 CIVIL TERM Plaintiff Vs. JASON L KECK Defendant IN CUSTODY COMPLAINT FOR CUSTODY 1. Plaintiff is Joanne R. Keck, an adult individual, currently residing at 169 Cedar Lane, Carlisle, Cumberland County, Pennsylvania, 17013. 2. Defendant is Jason L Keck, an adult individual, currently residing at 133 CME, Newville, Cumberland County, Pennsylvania, 17241. 3. Plaintiff seeks custody of the following child: Kady Renee Keck, age 3 years, born 10/26/96. The child was not born out of wedlock. The child is presently in the custody of Defendant, who resides at 133 CME, Newville, Cumberland County, Pennsylvania. During the past five years, or since the child's birth, she has resided with the following persons at the following addresses: (a) from birth to December 29,1999 with the parties at 133 CME, Newville, PA. (b) from December 29, 1999 to present with each party on an alternating basis, The natural mother of the child is Joanne R. Keck, , I, I' I: eo"._".'"',; She is married. The natural father of the child is Jason L. Keck. He is married. 4. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with 5. The relationship of the Defendant to child is that of natural father, 6. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the children in this or in any other Court. Plaintiff has no information 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The mother has been the primary caretaker of the child since her birth and is capable of providing the care a child needs. (b) The mother needs to have a Court Order as father has threatened that he will take custody of Kady from the mother and this concerns her greatly. 8, 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 II A-,. parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None WHEREFORE, Plaintiff requests your Honorable Court to: A) grant custody of the child to the plaintiff; B) set an emergency hearing in order to set the parties rights until such time as there can be a full hearing in this matter; C) grant such other relief as is just and in the best interest of the child including the award of attorney's fees against the father. Respectfully submitted, Date:~ ~\2a~~ Robert L. O'Brien, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 'I ,'-,' ",-,~, I verify that the statements made in the foregoing Complaint for Custody 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. ~ V,elf-- ANNE R. KECK -' DATE: ~ II ~""\ln7 '. r N\tf c~ , \ , . ... ,. c) CJ c5: '~ 0 .-1'1 c. u(L ?:;: :JJ' n1r"i'1 f-- ;-::=,:.; ''')JTl; Z(- cn :::<~ (;:- (I)~ -<-'- ':~~ ~i:~ reG 'U <: ~(') .....,. ~~~ _"l;... --0 ~ )>c: ~ "c> W S:l fv -< C2 n Vi ~ > ~ '" ;::;:; en 15 ?: f;; 0:: -< s: ;ll :r I:ll z :r > " z ~ :>::l 0 ~ c=; ~ 0 ~ < ;;; ... 8 > '" CIl Z S; ~ C"l ~ = :;j '" 0 -< 1::i w :>::l '.Jcl ~ ,I,. ~ '""-<- -. -, ^;q JOANNE R. KECK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs, CIVIL ACTION - LAW NO. 2000- 300 CIVIL TERM JASON L. KECK Defendant IN CUSTODY ORDER OF COURT AND NOW, this ~ay of ~ .2000. upon presentation and consideration of the attached stipulation and agreement and upon agreement of the parties, it is hereby ordered and decreed that the attached agreement is made an Order of Court. ~~ 5-11-00 RK3 i'IIIli*/lliWBllIi!UlI~~t~~~"'''''='^.~- l;\_"'illi~~~~ ,- ""- '.' " , V,?'\'I /i I/!0 ''''''12 .... , 11'\ 'v... <'I, n, /1"': ~j'''I\rll ......,./ n-~ I~VI v, {:'; :"'l ~, 'Jr~!:"r;! /,:::'d C -' 'J' ,0", "" '/ " "-"'h"., 'I( ,,' II ''-' f,J / 'v "(CitLQi,',, , , / I{ f!/.I Or ~ ~l...r-j /-~\, '> f.J ::/"'" ",<.",:;'_',_i __j' v/..1dO-~___-;/j . lJ';;l!:J ',I .;;'0 II'~ "~.., "-, l~ s..... ',I ..j I !I 'i ii ~I ~ ~ ! 'II ! I I' t! II I I ! i J _' .;j JOANNE R KECK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO, 2000- ,3:38 CIVIL TERM JASON L. KECK, Defendant IN CUSTODY STIPULATION AND AGREEMENT THIS STIPULATION AND AGREEMENT entered into this qt1J day of mOJlCJv ,2000, by and between JOANNE R KECK (hereinafter referred to as "Mother") and JASON L, KECK (hereinafter referred to as "Father"), NOW THIS AGREEMENT WITNESSETH THAT: WHEREAS, the Father and Mother are the natural parents of Kady Renee Keck, born October 26, 1996; and WHEREAS, the Mother and Father wish to enter into an agreement relative to the custody of the child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth and intending to be legally bound, the parties hereto agree as follows: 1. The parties shall have joint legal custody of the child, 2, The parties shall have equal shared physical custody of the minor child with physical custody to be shared in accordance with the respective work schedules of the parties, The following days shall be spent with the respective parent; .-J , ..I " , -~ Father: New Years Day, Easter Day until noon, Memorial Day, Father's Day, Labor Day, Father shall have Kady on their shared birthday, Christmas Eve Day to Christmas Day at noon, Father shall have vacation time as arranged through his Employer; and, Mother: Mother shall have Kady: New Year's Eve Day to noon New Year's Day, Easter Day from noon, Mother's Day, July 4th, July 29th, October 27th, Thanksgiving Day, Christmas Day from 12 noon, Mother shall have vacation time as arranged through her Employer and Father. It is anticipated that each parent will have two weeks vacation and the weeks will be non-consecutive unless mandated by the employer, When vacationing with Kady they will provide an itinerary and phone numbers, The parties agree that in the absence of an agreement otherwise, each day with a parent will commence at 8:00 a.m. and end at 8:00 p.m., unless the parent has Kady the day before or after. It;s the parties intent that Kady spend an equal amount of time with each parent throughout the year. 3, The parties will keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to ensure that the health, welfare and well-being of the child is protected, 4, The parties shall do nothing that may estrange the child from the other, or that may affect the natural development of the child's love or affection for the other party, , >~........ , I ,. -i..I 5, Both parties shall have reasonable telephone contact with the child during periods when the other parent is exercising physical custody, 6, Any modification or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. 7, The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other, 8, The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the parties' minor child and shall retain such jurisdiction should circumstances change and either party desire further or require further modification of said Order. 9, The parties also wish to provide that Father will cover Kady under his Blue Cross/Blue Shield health insurance and in return that Mother will pay all child care expenses. The parties agree that they will not seek child support from each other while they have equally shared custody. This provision may be modified in the event of a substantial change in circumstances to either parent or Kady, --<'-~"'-- ~-"'~ . ~ l . ~ , IN WITNESS WHEREOF, the parties hereto, intending to be legally bounded by the terms hereof, set forth their hands and seals the day and year herein set forth, WITNESS: ~L~tV-V-- (SEAL) (SEAL) JASON L, KECK Date:~ robldomestlc/kec k.sti pulation "~ ~.;. 'J_ ""~..' COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF CUMBERLAND On this, the /~ ~ day of mOA.d , 2000, before me, the undersigned officer, personally appeared JOANNE R. KECK, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledge that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~~~ Notary Public (SEAL) COMMONWEALTH OF PENNSYLVANIA Notarial Seal Angela F. Unger, Notary Public Carlisle Bore. Cumberland County My Commission Expires Oct. 7. 2000 : S :Member. Pennsylvania Association of Notaries COUNTY OF CUMBERLAND On this, the 9'~ day of &4c?~ , 2000, before me, the undersigned officer, personally appeared JASON L. KECK, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledge that he executed same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notarial Seal Kimberly l. Diehl-Hough, Notary Public Carlisle Bore, Cumbe~and COunty My C~mmission Ex ires May 5, 2003 ~:r~~~ / ' Notary lic ' (SEAL) ~f tAoooz 60 J.\tW .' " , , \ ! ! , 0 () ! Ol )- i" :>::l v; ~, m , EI z '" ~I Ol ~ >: m > E z ~I z :>::l S - '" C"> -< 1'\ , ... < ~I c: )- tIl Z C"> :;: :::: 'OJ m 0 :>::l W m :>::l (') a (') c c:> .,., :s: ;X "I "p ~,m fj'rp ~~~ r::B ~n L... -,-~ '" c., ~s;; z =<! .Dlt -< I CD ~~i:J1! . r- 2j,~? {'::,,'~r, ~f~ 3=J >~o <-m ~::; 1::>". ::0 -< .) ::;:;:' S-J Co,) ('...J , -'-""_'-J..<' -'-- ,,', (, ."'<i~"__:"'~'"ol , :~,'- ,-' " ;, '" I"", J "",,',; 'C '- -,,,~':,' J MAR 1 7 2000bD JOANNE R KECK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JASON 1. KECK, Defendant NO. 00-333 CIVIL IN CUSTODY COURT ORDER // AND NOW, this 1& day of March, 2000, the Conciliator being advised that the parties have reached an agreement, the Conciliator relinquishes jurisdiction. BY THE COURT, , " FILED-OFFICE O~r '~,'F C't:lnTI..~a"N'oTAl'lV '. '" I . ''-''~ 1l'Vl' 00 t1AR I 7 PH 2: 39 CUM8ERUWD COUMY PENNSYLVAJ\I/A ,,-,' -" "_,~__ ,'~__y,^, __,_''-"9' -" _. " _~ M ......_~.,.~ ", -"'-~~ ~ 'm~_' _a" '. ,_ . ,." ~........~ t~~1!I!1I!!! -~ ~~" ,L ., L< I#- _~ f JOANNE R. KECK IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA v, 00-333 CIVIL ACTION LAW JASON L. KECK DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Friday, November 01, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Hubert X. Gilroy, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, November 14, 2002 at 8:30 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 couciliator 48 hours prior to scheduled hearin~. FOR THE COURT. By: /s/ Hubert X. Gilroy. Esq. ~v 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 THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HA VB AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 "7, f:)~.ED-Oi:flC,:Xn"'^' "-~r ,.__,_ Il"I'",/lr,RY l,)l- I"~ ',""'11 _', DI;I~: II ,J! [':":1_\" ~i I I . ",. ,', ("'-'UNrrv ClJt'~~bt.H\).;.hL) v-J I n 1 PEi,jNSYLVA\JIA it 40;;2 U~ ~~ ~?t 4 ?J~ /f'ij-o,;> '71~~ ~~. /I'lf-o~ ~ ~ ~ aZJ ~ TIl" ~ . ,.~ -~-' , ~ ~ ~~ ",_"~~,,,_._'!'IlW!l_ml .,=~,,"""" o~~,,~~if: 'Il"f1' li_flI!llit'!!!~ .;~c~ L, ~,~-, -' ~. , r JOANNE R. KECK Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2000-333 CIVIL TERM IN CUSTODY Vs. JASON L. KECK Defendant ORDER OF COURT AND NOW THIS _ day of , 2002, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before , the conciliator, at on the _ day of , 2002 at _ A.M.lP.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. 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. BY THE COURT, BY Custody Conciliator 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 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 THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OF 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 ~ '''Illi._; -' c . . , JOANNE R. KECK, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-333 CIVIL TERM JASON L KECK, Defendant CUSTODY COMPLAINT TO MODIFY CUSTODY 1. Plaintiff is Joanne R. Keck, an adult individual, currently residing at 1575 Webster Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Jason L. Keck, an adult individual, currently residing at 10 Mountain View Terrace, Newville, Pennsylvania 17241. 3, Plaintiff seeks custody of the following child: Kady Renee Keck, age 5, born October 26, 1996. The child was born during the parties former marriage. The child is presently in the primary custody of the Plaintiff with partial custody in the Defendant. A copy of the existing Order is attached. This Order was based upon a work schedule for the Father which has since changed. For the past year or longer the Mother has had the child in her care for three quarters of the time. During the past five years, or since the child's birth, she has resided with the following persons at the following addresses: (a) from birth to December 29, 1999 with the parties at 133 CME, Newville, PA. (b) from December 29, 1999 to the latter part of 2001 with each party on an alternating basis. ,J.....,. ,~ , , . , -' . , (c) from the latter part of 2001 to the present with the actual primary physical custody in the Mother and partial physical custody in the Father. The natural mother of the child is Joanne R. Keck. She is single. The natural father of the child is Jason L. Keck, He is married to Rachael Keck and they have a child Faith, age 5 months. 4. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with her daughter and her boyfriend, Chris Jumper. 5. The relationship of the Defendant to child is that of natural father. 6. Plaintiff has participated as a party concerning the custody of the children in this Court as evidenced by the attached Order. Plaintiff has no information 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. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: (a) The mother has been the primary caretaker of the child since her birth and is capable of providing the care a child needs. (b) The mother desires to have a court Order that accurately reflects the status quo for the past year that she has had primary custody of her daughter. ,~ '~~~~ " - ~- -~" , - . 8. 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. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene. NAME ADDRESS BASIS OF CLAIM None WHEREFORE, Plaintiff requests your Honorable Court to: A) grant primary custody of the child to the plaintiff; B) grant times of temporary custody to the defendant; and C) grant such other relief as is just and in the best interest of the child. .kz Robert L. O'Brien, Esquire" O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 (717) 249-6873 During the past five Date: /6Jzf /~7., I { ~~~........ ~- _, J ,~ . . , I verify that the statements made in the foregoing Complaint To Modify Custody are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904, relating to unsworn falsification to authorities. ~o. ,J2t0~ Joanne R. Keck DATE: 10 -23-02- ___~__IIMiliIliilIlWrio. _.~:!it;j@~\jj-;i;'''~~,,"Hrn~~illOI''" .'n - fl.-iIIIl- ~~ ~ ~ ~"'""""""'- -- -.tq. B \) () ~ ~ '----'--. ~~ w \) ......... w ~ C) r --..c::. 2 ~. ".':>" "'UG'. ,T\f"~; ""7-[: ~~:. -<..-- G:C':; ~G -c- (J PC:: ~ -~ " ~ o 1'''>,.J o {:"') --I N .t:"' .. n ~.\ -1'- .l c;- J'~ :;l1:: '-P. t:'" ~ ~/}~>, ~2~~1 ~ft'\ 9 ". ~ , ""~~"~"''''''r'.-''''-' . ~~ ~~- ._ L _, .L. ;'dA:~f.[,i,:" . < NOV 1 8 2002 ~ JOANNE R. KECK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JASON L. KECK, Defendant NO. 00 - 333 CIVIL IN CUSTODY COURT ORDER ~ AND NOW, this -.li day of November, 2002, upon consideration of the attached Custody Conciliation Report, it is ordered and directed that the prior custody orders entered in this case are vacated and replaced with the following order: 1. The Mother, Joanne R. Keck, and the Father, Jason L. Keck, shall enjoy shared legal custody of Kady Renee Keck, born October 26, 1996. 2. The Mother shall enjoy primary physical custody of the minor child. 3. The Father shall enjoy periods of temporary physical custody of the minor child as follows: A. On alternating weekends from Friday evening through Sunday evening, at a time that is agreed upon by the parties. B. At such other times as agreed upon by the parties. 4. The parties shall also share/alternate custody with respect to holidays, the child's birthday and other important days as the parties have done in the past. Additionally, each party shall be entitled to summer vacation with the minor child as the parties have agreed upon in the past. 5. In the event either party desires to modify this order, that party may petition the court to have the case again scheduled with the conciliator. h-t George E. Hoffer cc: /Robert L. O'Brien, Esquire t hason L. Keck > fl ~ 10 Mountain View Terrace L Newville, PA 17241 -AXs J. .... /I -j r -0 ~ " '-,- , . ~M ~ , .,..,. ~~,- 02 j}C'J CII,\(.., \J"... .. ',",j -, ..'-.,". ,-" ~E;<~\j-3 .', \{{iif1Y IQ . .' ,'). ')/, .J' ,l~ CC!U\~T\( {L~'.i>'!,i\li/~ _~~J!!lI!!U, ~Ul ~ .'" ,iI"9II'l'l'''>-~ _OT ,~~~. ~_..,!!!lI'f!'leh~_~"-~ Tr ~~. '-:;--;0",-.;,;,--:'--, _'-_:-;"k~':_"':::_' " # JOANNE R. KECK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW JASON L. KECK, Defendant NO. 00 - 333 CIVIL IN CUSTODY Prior Judge: George E. Hoffer CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Kady Renee Keck, born October 26, 1996. 2. A Conciliation Conference was held on November 14, 2002, with the following individuals in attendance: The Mother, Joanne E. Keck, with her counsel, Robert L. O'Brien, Esquire; and the Father, Jason L. Keck, who appeared without counsel. 3. The parties agree to the entry of an order in the form as attached. 1,( (rf 0.( DATE Ot(