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HomeMy WebLinkAbout00-01129 '~~~::''''O'':''''';' .,.;......^"':;a..;'."":o::.....""-....~..,'';.'''::..~..,'''.''::....''..,;'''.:<<;,.~....."..,' 1e....",.......;..., ".:....~,.'.'''.:....;,' .'.;~..w .;.~W'1+".:....;"'.<."':.......". ..,;"':....;.,.".;".:..";"V.~of"l'::+.;~....".;':+}"''O;:+},'...".'':4l;~~';T....':->.':C."'.....;."'.:~.'.'~{I,":<<'~',;,":<<'~!4. K .,...., "" ,a,'. "" ."-'" "".,'''''''", - "'-.....,., ""...""" ~~. .','" ".S", ..."'.~ '::':",~'''' '" ,.?'~... ""~.~'" ",,,,'," ..~,.-'.'" ~""'''' ""~,.,,, .._^.,~ ,...".'''' ,"",""" '...., ",,,"." .'~"'~_~ ',.N" ""-~,.~ ""~"'.'" ~""."'''' "',"''''''' ";',.d. """"''''i ~ ~ ~'1 ~..~ 'W' ~,' ~ IN THE COURT OF COMMON PLEAS ! ~ , "" t) ~ OF CUMBERLAND COUNTY ~ ~ ~ ^ ~ ~ ~ x ~ ~ STATE OF PENNA. ~ ~'" r,< ~.~ ~ ~ ~ X ~ $ ."."..~()~,A.J:"IJ,.:E:,__,I<l'.F;13:E:~!'\'l.'.......,..,....,__...... II ~ ~ PLAINTIFF N o. ..~.~.~.0.::.1..1..?9 .................:t~ N B ___.._____....h__.......___h....._..__.....___........u.......V.'_......__'....n' I ~ ~ Versus I Ni ~.~ .~ ~ ...............:s.-!\I<.,B.~.~~.-!\"..I<E:E:S,E:l'll\~.,............'m.... I ~ ~ DEFENDANT ; ......'.....,... ...m'....m.......'.......'.....,.................. ..,..m..,...' !'j .~ ~ f.~ f~, ~ < y i V DECREE IN l'~ ~ ~'S f:, ~ ~ ~~ !.' DIVORCE ~ ~ . ~ ts ;~ ~ ~ i AND NOW, . . . . . .. . . . . .a.p"'...J::. . . '1.. '. i'lj. ~~.O.~, it is ordered and ~ ~ decreed that. .. .. .... ..... .~?!'l!l:~I? ~.'. .~?!".~E:~~... ........... plaintiff, ~ N a ~.' and........................ ~~~~~~.l; .1;.'. .~F!~?!'.~t:l.........., defendant, !~ .~ ~ ~~ N ~ are divorced from the bonds of matrimony. ~ ~ ~ ~ The court retains jurisdiction of the following claims which have q ~< ~ $ been raised of record in this action for which a final order has not yet ;1 ~, been entered; ~ ~ ~ ~ :r:FJJ? ?}\~n;E.<i :~RJ;'J;'l;\.j:,. .<ienLE;~EN:r. .AGREEMEN.'C, .DA'CED. J.ULY. 3.1.,;!P.o.Q., ~ 1; .~~ . ~~.~E:J??'. ."!~I?? .F., . ~~~.F.,J;.. 9.R.QE:~. 9F: . 99.u:~~,. . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~ '.~., . - ~.: ~~,: $ " '" $ 0'. ~~~ ~ ,".. '.,' S ~ i ~ ~ I. ?...X7oa.::.., ~<"',:.<4".....-' .., ~"~ ~ By C~/:JJi ..............,.................. ~tte.t.:...,"',..~aa:i. !:! "I >t._ .' ,', ~ ~ ~.~ J. ,', ~ ;;i '.' ....- - ........... Prothonotary ~ ~.4 ~ ~ :~:.t.::~.,. '~..::+::~:: :,,::+,.~ ~,,::+,:;.,:'..::.::.;, '~.::+::~,: ".::+,.: "'::+::~ ~::+::.,' .::+::., .::+::., '.::.::. '::+~.. ".::+X x+;.~~{.::.,: >~::~: ;~::+>,_: ;.::+::.', .'.::.::'" ::.::.::":: .::+;. ::.::+;:t ~ ~.' , ... ..,...,...... t'..... ~ :-~ 'to ...'. *' . ..~_ . ff-/~-&O W. ~ ~ ~ 4 ~ ~/11"4? '71~ IU~ 7f; 4- ~ . ., . , . . , .....-. , '!' ~ " -~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.2000-1129 CIVIL TERM RONALD E. KEESEMAN, P lai ntiff BARBARA A. KEESEMAN, Defendant CIVIL ACTION - LAW IN DIVORCE MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this ~ day of .J/.,U\J / , 2000, by and between Barbara A. Keeseman, hereinafter referred to as "Wife", and Ronald E. Keeseman, hereinafter referred to as "Husband." WITNESSETH: WHEREAS, the parties are Husband and Wife who were married on March 21, 1998, and have been separated since March, 2000; and, WHEREAS, Husband has instituted divorce proceedings in the Court of Common Pleas of Cumberland County to No. 2000-1129 Civil Term by complaint filed on February 29,2000; and, WHEREAS, the parties do not have any children together; and, WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and the parties have decided that their marriage is irretrievably broken, and it is the intention of the parties to live separate and apart for the rest of their natural lives. The parties are therefore desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including without 1 , ' < limitation: the ownership and equitable distribution of all property owned by the parties; and the settling of all related economic claims including but not limited to spousal support, alimony and alimony pendente lite; and in general the settling of any and all claims or possible claims of one against the other or against their respective estates; and, WHEREAS, each party is fully familiar with the all of the property owned by the parties and each party acknowledges having sufficient opportunity to investigate and evaluate the property owned by the parties, and both parties now desire to settle and determine his and her property rights and claims under the Divorce Code. NOW, THEREFORE, in consideration of the mutual promises hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, the parties, intending to be legally bound hereby, do covenant and agree as follows: 1. DIVORCE The parties agree to the entry of a Decree in Divorce pursuant to Section 3301 (c) of the Divorce Code. 80th parties shall execute and file the requisite Consents and Waivers with the Court contemporaneously with the execution of this Agreement. Husband's attorney shall file the Praecipe to Transmit the record and obtain a Decree in Divorce without delay. Should either party do anything to delay or deny the entry of such a Decree, or fail to do anything required to obtain the Divorce Decree in breach of this Agreement, the other party may, at his or her option, declare this Agreement null and void. 2 . . , , 2. INCORPORATION BUT NOT MERGER INTO DIVORCE DECREE This Agreement and all warranties and representations contained herein shall survive the Divorce Decree and shall continue to be enforceable in accordance with its terms. An action may be brought at law, in equity or pursuant to the provisions of the Divorce Code to enforce this Agreement by either Husband or Wife. 3. ADVICE OF COUNSEL Husband is represented by Michael A. Scherer, Esquire, who is his separate legal counsel. Wife is represented by Jacqueline Verney, Esquire, who is her separate legal counsel. Both parties acknowledge that they have had sufficient opportunity to confer with counsel prior to signing this Agreement. Husband and Wife acknowledge that each of them has read this Agreement and understands his and her rights and responsibilities under this Agreement, that he and she have executed this Agreement under no compulsion to do so but as a voluntary act, being apprised of its consequences. 4. TANGIBLE PERSONAL PROPERTY Wife shall become the sole owner ofthe 1999 Saturn automobile. Aside from the foregoing, the parties have divided between them to their mutual satisfaction all items of tangible personal property which had heretofore been used by them in common and neither party shall make any claim to such property titled in the name of the other party or in the possession of the other party. Each party will execute any and all documents necessary to effectuate the transfer of ownership of any items of personal property tilled in both names as set forth above. 3 , < , ' . 5. OTHER PROPERTY DISTRIBUTION PROVISIONS A. REAL ESTATE: Husband owned 193 Quigley Road, Newburg, Pennsylvania prior to the marriage. Wife hereby relinquishes to Husband any ownership interest she may have acquired in said real estate by virtue of the marriage. B. WAIVER OF RETIREMENT BENEFITS: Wife hereby releases any ownership interest she may have acquired by virtue of the marriage in any pension or retirement benefit earned by Husband, including the pension/retirement account Husband has with the Beistle Company in Shippensburg, Pennsylvania and Waste Systems International, Inc., 142 Vaughn Road, Shippensburg, Pennsylvania. Husband hereby releases any ownership interest he may have acquired by virtue of the marriage in any pension or retirement benefit earned by Wife. C. INTANGIBLE PERSONAL PROPERTY: Wife shall be entitled to keep as her separate property the $3,000.00 she removed from the Allfirst Bank Account. Aside from the foregoing, the parties have divided between them to their mutual satisfaction all intangible personal property consisting of cash, bank accounts, annuities, securities, insurance policies, certificates of deposit and all other such types of property. The parties hereby agree that all such intangible property presently in the possession of or titled in the name of Husband shall be his sole and separate property, and that in the possession or titled in the name of the Wife shall be her sole and separate property. 4 . . , , 6. DEBTS AND OBLIGATIONS Each party represents that she and he have not heretofore incurred or contracted any debt or liability or obligation for which the other may be held responsible or liable. Each party agrees to indemnify and hold harmless the other from and against all such debts, liabilities or obligations of any kind which may have heretofore been incurred by them individually. 7. INDEMNIFICATION Both parties covenant, warrant, represent and agree that each will now and at all times hereafter save and keep each other indemnified against all debts, charges, or liabilities incurred by the other after the execution of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and neither ofthem shall hereafter incur any liability whatsoever for which the Estate of the other may be liable. Each party further agrees to indemnify and save and hold harmless the other from any and all liabilities he or she may incur upon the obligations of or assumed by the other, which indemnification as to all provisions of this Agreement shall include the right to recover out of pocket expenses and reasonable attorney's fees actually incurred. 8. EQUITABLE AGREEMENT Both parties agree that the hereinabove set forth Agreement constitutes an equitable distribution of their marital property and equitable resolution of all other economic claims pursuant to the provisions of the Divorce Code and each party irrevocably waives, releases, and remises any claim to ownership of or interest in any 5 . . . , , , . property designated as the property of the other by virtue of the provisions of this Agreement except as otherwise may be provided pursuant to the provisions of this Agreement 9. MUTUAL RELEASES Husband and Wife do hereby mutually release, remise, quitclaim and forever discharge the other and the estate of the other from any and all claims either party has now, ever may have or can at any time have against the other or the other party's estate or any part thereof, whether arising out of formal contracts, engagements or liabilities of the other party, arising by way of widower's right or under the Intestate Law, arising by any right to take against the Will ofthe other party, arising out of the Divorce Code, Act No. 26 of 1980, as amended, including, alimony, alimony pendente lite, counsel fees and expenses, arising as a right to spousal support or arising from anything of any nature whatsoever, excepting only those rights accorded to the parties under this Agreement 10. BREACH If either party to this Agreement resorts to a lawsuit or other legal action pursuant to the provisions of the Divorce Code or otherwise to enforce the provisions of this Agreement, the successful party shall be entitled to recover his or her reasonable attorney fees, actually incurred, from the other as part of the judgment entered in such legal action, whether in law, in equity, pursuant to the provisions of the Divorce Code or otherwise as the same shall be determined by the Court. 6 \ , > 11. ENTIRE AGREEMENT This Agreement constitutes the entire understanding of the parties. There are no covenants, conditions, representations or agreements, written or oral, of any nature whatsoever, other than those herein contained. 12. MODIFICATION This Agreement is subject to modification only by a subsequent legal writing signed by both parties. It shall be construed according to the laws of the Commonwealth of Pennsylvania. 13. AGREEMENT BINDING ON HEIRS This Agreement shall bind and inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 14. CONTRACT INTERPRETATION For purposes of contract interpretation and for the purpose of resolving any ambiguity herein, Husband and Wife agree that this Agreement was drafted and prepared jointly by their respective counsel. 15. SEVERABILITY AND INDEPENDENT COVENANTS The parties agree that each separate obligation contained in this Agreement shall be deemed to be a separate and independent covenant and agreement If any term, condition, clause or provision ofthis Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and in all other respects this Agreement shall be valid and continue in full force and effect 7 , . . . 16. COSTS AND ATTORNEYS' FEES Neither party shall reimburse the other for any court costs or filing fees associated with this case, and each party shall be responsible to pay his or her own attorneys' fees. 17. WAIVER OF ALIMONY Husband and Wife do hereby waive, release and give up any rights which either of them may have against the other to receive alimony or other post-divorce spousal maintenance or support. WITNESS: ~~ ~ +~MI k C 4Au4 Ronald E. Keeseman ---- ~k,L- 'J- ~~~.~. Barbara A. Keeseman . . '- . . 0 c::> 0 C- O " ~.. ;::: -nr::.r p-\ n 2"'5 " i~'::: Z ~~-~. , .. c:~ :z (.q c.; : -<- i.:.', I::~ r;:; s: ',' ~Q ::r; ~:~" ~~ L u :>:-- ....~; 'R ,So m c: ~ z " ",. --' ~ -< ,:;> , " , RONALD E. KEESEMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW BARBARA A. KEESEMAN, Defendant NO. 2000-1129 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 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant signed an Acceptance of Service on March 3, 2000. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff on July 31 , 2000; and Defendant on June 1, 2000. B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) date of service of the Plaintiffs 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 June 1, 2000 and Plaintiff on July 31, 2000). Respectfully submitted, ~U~~ Micliael A. Scherer, Esquire Attorney for Plaintiff, Ronald E. Keeseman C) c ;?: ""1)','-' nIt,,, ~tL ej) ,;? -<, r::c. ~-" ~~ z ~ -< , ~ o co r::: c=; , "- ',:::-:> " .~,; =~: -' ;,~M: !:..,~ :....~ '~I ;,~ =< 1..0 '" ~ t "," .' , RONALD E. KEESEMAN, P lai ntiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000- !/d.-f CIVIL TERM BARBARA A. KEESEMAN, Defendant 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 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 , , .' RONALD E KEESEMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA v, NO,2000- //;29 CIVIL TERM BARBARA A KEESEMAN, Defendant CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301 rC) AND 3301 (D) OF THE DIVORCE CODE 1, Plaintiff is Ronald E Keeseman, an adult individual who currently resides at 193 Quigley Road, Newburg, Cumberland County, Pennsylvania 17240. 2, Defendant is Barbara A Keeseman, an adult individual who currently resides at 193 Quigley Road, Newburg, Cumberland County, Pennsylvania 17240. 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 21, 1998 in Newville, Cumberland County, PennsylvaniR 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 he 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, . . . " - WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, By O'BRIEN, BARIC & SCHERER 1ffia/~~~ Michael A. Scherer, Esquire 1.0. #61974 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 Attorney for Plaintiff, Ronald E. Keeseman ." . "" VERIFICATION 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. S 4904, relating to unsworn falsification to authorities. ~~~Zh~ Ronald E. Keeseman Date: {);J-J.S-OQ 'c . . c.~ ..-., RONALD E. KEESEMAN, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-1129 CIVIL TERM BARBARA A. KEESEMAN, Defendant CIVIL ACTION-LAW ACCEPTANCE OF SERVICE AND NOW, this 3rd day of March, 2000, I , Barbara A. Keeseman, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa. RC.P. 1920.4(e) and acknowledge receipt of a true and attested copy of said Complaint. b~ Q. ~OMQ ;N'Dfv. Barbara A. Keeseman < : . , .,'0...' ........;. . . .. ..-.... '.'; :'~.:-::::: _.~..N_~__,_ ': -~;' ~~,.::- >, . : ::. "'- ~"~'li,!U;J:: ':~ '._~".:2:- ..i':l~~>i: ','\ ~--- ,- :"~.' ...:...:>.~ -,,~'f:.' '." ~. .' 81 i-;;"_.~~2 :~.Y: "~ '_" <2-~J~t...;x~s: .{J'!t :~. '......-:~3;~.~. J~:-~/~~ - ~-- -..-,.. t:'~.,- ".~-~. '..-< -',. .~- -. ->~ -. ., ~ ot:; :.~' ~:: '~~~;::~-' ....~,- ''':'-' ,~-~ "...... ,1,.~.;<~~:::.~S3.'::~ : "::;'" -:"'.- '~"~'-:i:': ;E;'-~' ,.,~ ~...~ ~;":"i-t.. '-." (") 'c. s: -Ow fTJ rr I 2::0 2C- C/) =-; ~6 ~O SO "C:, 2 =<! ~;C;it;::,';:.~~:.:' . ;-" :~. ~ ," .' ",' -~~ :"',~~~S.':'.~ '-, -.-- . C> C> <- c:: ~ N "" V ::.:: ~. <:- ..,.. o -n ::;:} i-h:;g -.-di1 ""9 (~() ::l:=R o'M' .2::.... e~'\ ~r :> :rJ ;;. ;~ ;..:, ;. "fL', .It .-7~S~.~ ", .. l(" ,.., .. '" .... II' RONALD E. KEESEMAN, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-1129 CIVIL TERM BARBARA A. KEESEMAN, Defendant CIVIL ACTION-LAW PLAINTIFF'S AFFIDAVIT OF CONSENT 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 February 29, 2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 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. 5. 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. 6. 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: J(fL, r ,)fj ~O(JD , ~~~. Ronald E. Keeseman < ~ . .- -- ".. ... .- ... 0 = 0 c 0 -;1 S ~ -oc;:: 92S~, S ,- z c ~ S2~~:: ~. ,~:; - ,- ,<C :::"""'; - - " -n ):...- (~ ~O '..c t~IY' J"C ~ Z '-.' ':.~ ~ 0 ~ ~- ... - ~ . -- ........ . RONALD E. KEESEMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO. 2000-1129 CIVIL TERM BARBARA A. KEESEMAN, Defendant CIVIL ACTION-LAW DEFENDANT'S 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 February 29, 2000. 2. Defendant acknowledges receipt and accepts service of the Complaint on March 3, 2000. 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: (, -I -00 ~ 0.. ~SVIY\Q/v\' Barbara A. Keeseman . - - ._-~ ~ ~ ~ . 0 0 Q c: <:::) " s: <- .-t -oel) c:: r;'1;22 mrn :;e Z::u N ::2.1T1 e;~ <.0 ",9 -<-<::: ..~"5S~ '-c -0 <: ,~~:n :J>~ ::z ::::::"....-/ '-.C" 5>8 ~ [5rn ~ s::- ~ - -< - RONALD E, KEESEMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLV ANIA V. CIVIL ACTION - LAW NO. 2000 - 1129 CIVIL TERM BARBARA A. KEESEMAN, Defendant IN DIVORCE NOTICE OF INTENTION TO RESUME PRIOR NAME Notice is hereby given that the Defendant in the above matter, having been granted a final decree in divorce on the 9th day of August, 2000, hereby intends to resume and hereafter use the previous name of Barbara A. Summers and gives this written notice avowing her intention in accordance with applicable law. &ulwo~ O. Aoo/)Orrro.~ Barbara A. Keeseman To be known as: f?{)"fxJJn 0.., JumV11'IQi.Q Barbara A. Summers COMMONWEALTH OF PENNSYLVANIA ss 111-01'2.,-- 7~~8 COUNTY OF CUMBERLAND On the c;J. { 9ayof fiu<:'usf-, 2000, before me, a notary public, personally appeared Barbara A. Summers (forme'rly known as Barbara A. Keeseman), 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. NOTARIAL SEA DENISE PINAMONTI. No Public Carlisle Borough. Cumberland M Commission Ex ires_Nov. 20, 2000 hand and seal.n , f1).Mf*ctfl', y Public IN WITNESS WHEREOF, I have hereunt ~ .:, t<:::> ~ 0 0 Q ~ c: 0 <' " ~ -N -occ "'" :~ mrn c:: ;...;::o:-n 7,' G') g Z:C N -'-r ~ (/) ,..- w -"i? -<"'-:... ~ 1'<0 ,.'") )> """ ~~S~ ZO ::l1: r:.;:D -.;;. ~ 5>0 ~~O ~ - ani c: .. z: -; r-- ::< N ~ "" "'~