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HomeMy WebLinkAbout00-02125 '. " t '.........""._",'...-:.-1',......-w_.:.w'.........""".,J=.............'''"........."'''''/_'''''''_'~''I ~,_~"j'.....,-.~~..._~:~J!~....:_I;',.~..!........#!,~''\>!.....L0":,<!.......#!";:,~!..,,.L.,','!..............,;,!......~''''! . '~ ~ I ~ I ~ ~.~ ~ .;<,. a ~.~ ~.~ ~ .""; ~.~ . ~.~ i ~.~ ~ ~.~ I ,", ~~~ ~ i ~.~ . ~.~ ~.~ . - -::~+::.~~:.\~!tc~;:i~;+~::~!>>x::(+::.::!;:: ;..; I "." w ~ ~ ~ R ~ ~'.~ ~ ~ ~.~ "'.'" w ~.~ ~.S I ~ S , i i I I I I I I , r. II' i, !! I i I I f , " il !i ! !, II !i " II II II 'i ii [, tl II fl ~ [j !! :1 'I ~[ .".... ~ !I.~ ;..~ ~ ~.~ ~ iA ;.'~ ~ ~ ~.~ ~.~ I ~.~ ~ ;,; ~ .f~ ....~ ~ ki ~ '~,:" '.;, W i ~ ~ h ~ ~ ~'s ~ 8 ~':~ ~ ~~~ ~ ~.~ ~ .", ~.s ~ i.'~ I ~i . 7'; M i '...::!;;::;.>>::!." ~ ~..~ ~ ~~~~~~~~~~~~~~~~~~~~~ .~::{:::+:+>t:~<C~::~!...(:~!::CK)::C~~)::.::~ )3:()::.x::~~::.:::~;:'x.:(::~+tc~;::-;~~.::!~;:::::<.::i{ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. WILMA L. KEESEMAN, I II ..................19 N 2000-2125 0......................... Plaintiff Versus RICKY L. KEESEMNN, Deiliendant AND NOW, DECREE IN DIVORCE a-S~ ~pP1 . . . . . . . . . .8. . . . . . . . ,U'!P., it is ordered and Wilma L. Keeseman I . 'ff decreed that ................................................., p amtl , and..................... ~~~~~.~:. ~~~~~~~?................... 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 Marriage Settlement Agreement dated July 18, 2000 is .................. ~~99~P9P?t~~.P~~~~P. PY.~~f~~~pp~,. PP~. ~~ PP~. ~~~q~~ ~p~o the Decree in Di~grce. The Court retains and/or reserves ' .................. jur~sidictaon' over. ~h~s.ma~~e~.~n. accoTdano& wi~h 'said" Agreement and specifically paragraph 13 thereof. ..p. . ~~. o. ! '1 . < -I~"" , I " ~.S ~ lli ~~~ I :;~/~ - ;~ ;~ ~ """ ~.~ ~ ~ ~ ~~ ~.~ * '''I ~ ~." ;;-.; ~ li'.<! "'~ ~~" ~ ~.~ ~ f." ~ ~ ~ ~ ~.~ ~ ~.~ J. w. ~.~ N ~ ~ ~.~ i ... ~ ~.~ ~ 'l liM:~",.......l"",".,iW_'_'-' -' ,- ~..........._-,.~ ,- "~.~~.-.;..~" "~1II'" 1l " '"~ "'-"-~- ,- C'I . '.":" ',! . '~ ~, ~ - '. it Ji/ - t ~'&JaJ~~~ -$' , ~ l-Jtf-t)() ~ ~ -z; ~ ~ - .' 111;11ll;~1" U,.~" ilL."., " ."" "'" '" u . " -~. -, ~ . 'I '" J MARRIAGE SETTI,EMENT AGRF.F.MENT ~ ~. THIS AGREEMENT, made this Jr day of ..:ru V ,2000, by and between RICKY L. KEESEMAN, hereinafter referred to as Husband, and WILMA L. KEESEMAN, hereinafter referred to as Wife, WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married on November 14, 1982 in Newville, Cumberland County; and WHEREAS, there are no minor children; and WHEREAS, diverse unhappy differences, disputes, misunderstandings and difficulties have arisen between the parties as a result of which they have agreed to live separately and apart for the rest of their lives; and WHEREAS, the parties desire to confirm their separation and make arrangements in connection therewith, including the settling of their property rights and other rights and obligations growing out of their marriage; and WHEREAS, Husband and Wife are satisfied that they understand the value and extent of all property which would be considered "marital property" under the Pennsylvania Divorce Reform Act, whether titled or owned separately or jointly, as well as the value and extent of "non-marital property" held or expected to be held by each other; and WHEREAS, it is the desire of the parties to effect a complete and full settlement with respect to any and all claims, obligations, rights, duties and responsibilities of the parties with respect to the marriage, including but not limited to financial and property rights and obligations between each other, in accordance with the provisions of the Divorce Code. ..,.,.." ,'.1-".-.:' I !..c:;Iilliln1 ~ T .. 2 NOW, THEREFORE, considering the above conditions and circumstances, and in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration, and intending to be legally bound hereby, it is agreed as follows: 1. It shall be lawful for each party at all times hereafter to live separate and apart from the other party, at such place or places as he or she from time to time may choose or deem fit. 2. Each party shall be free from interference, authority and control, direct or indirect, by the other as fully as if he or she were single and unmarried. Neither shall molest the other or compel or endeavor to compel the other to cohabitate or dwell with him or her. 3. Wife relinquishes her inchoate intestate right in the estate of Husband, and Husband relinquishes his inchoate intestate right in the estate of Wife, 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 a matter or thing done, omitted or suffered to be done by said party prior to and including the date hereof, except that this release shall in no way affect any cause of action in any absolute divorce which either party may have against the other, nor shall this release affect any cause of action which either party may have against the other of whatever nature, arising or which may arise, under this Agreement or for the breach of any provision thereof. -'I ~.~.=~"~ 3 4. Nothing contained in this Agreement shall be deemed to prevent either of the parties from maintaining a suit for absolute divorce against each other in any jurisdiction based upon any of the grounds for divorce specified in Section 3301 of the Pennsylvania Divorce Code. In the event any such action is pursued or initiated, the parties shall be bound by all the terms of this Agreement. This Agreement may be submitted to the Court for approval pursuant to the Pennsylvania Divorce Code, with a request that it be incorporated into the Final Decree; and, in any event, this Agreement shall survive any Divorce Decree, shall continue in full force and effect after such time as a Final Decree in Divorce may be entered with respect to the parties, and continue to be enforceable in accordance with its terms. 5. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Pennsylvania Divorce Code, and have taken into account all considerations set forth therein. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and a division is being effected without the introduction of outside funds or property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights and any other rights of the parties. 6. The parties have divided between them to their mutual satisfaction the personal effects, household furniture and furnishings, and all other articles of personal property which have heretofore been used by them in common, and neither will make any claim to any such items which are now in the possession or control of the other, except as otherwise set forth in this Agreement. This Agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the I 4 parties hereto, and should it become necessary, the parties each agree to sign any titles or documents necessary to give effect to this 'paragraph upon request. Any household items which remain unclaimed by either of the parties shall be sold and the proceeds thereof shall be distributed to Wife. 7. The parties hereto are owners as tenants by the entirety of real estate situate at 101 Gameland Road, Newville, Cumberland County, Pennsylvania which consists of approximately 2 acres and is improved with a 2 story brick fann house. The parties agree that they shall sell this real estate (currently under contract for $93,500) and after the deduction of ail legitimate costs associated with the sale thereof, including real estate commissions, if any, transfer taxes, attorney fees, etc., and the payoff of the mortgage at F&M Trust and the payoff of the line of credit at F&M Trust, the net proceeds from said sale shall be divided such that Wife shall receive the first $5,000 of the net proceeds from the sale and after the payment of the $5,000 sum to Wife, the balance of the net proceeds shall be divided equally between the parties hereto. Until such time as the real estate referred to herein is actually sold and settlement completed the parties will continue to share the marital obligations, including the expenses related to the marital residence and the credit card debt, in the same manner that they have been sharing such obligations heretofore. 8. The 1991 Chevrolet Truck currently titled in joint names shall become the sole and absolute property of Wife and Husband relinquishes any and all right, title and interest he may have in said vehicle and Husband further agrees to execute any and all titles, sales and use tax fonns, and any other documents necessary to effect this transfer to Wife. , '''-''~-'~1- 5 9. The 1993 Chevrolet Extend-cab Truck currently titled in joint names shall become the sole and absolute property of Husband and Wife relinquishes any and all right, title and interest she may have in said vehicle and Wife further agrees to execute any and all titles, sales and use tax forms, and any other documents necessary to effect this transfer to Husband. 10. The parties hereto have divided between them their checking and savings accounts and all such accounts individually in the name of either of the parties hereto shall be and remain the sole and absolute property of said party. 11. Husband shall assume and be responsible for the payment of the following debts: First USA in Husband's name individually in the approximate amount of $9,500; MBNA in Wife's name individually in the approximate amount of $5,400; MBNA injoint names in the approximate artlount of $9,100; Cabelas Visa in joint names with an approximate balance of $4,700; Sears in joint names with an approximate balance of $4,500; Sears Plus in joint names with an approximate balance of $2,000; Walmart in joint names with an approximate balance of $900; and Montgomery Wards in joint names with an approximate balance of $500. Husband shall indemnify and hold harmless Wife from any and all liability and/or claims and/or damages and/or expense that Wife may sustain or for which she may become liable in anyway whatsoever with regard to these debts and obligations. In addition, Husband agrees to contact each and every creditor listed above and take any and all steps reasonable in order to remove Wife from any obligation whatsoever on the above referred to obligations . : I . .,.- I' 6 12. Husband relinquishes and waives all right, title, claim or interest he may have in Wife's retirement plan through the Public School Employees Retirement System and agrees to sign any releases that may be required to effect his reenunciation of any interest in said retirement plan. 13. Except as otherwise set forth herein, Wife relinquishes and waives all right, title, claim or interest she may have in Husband's retirement plan through the Cumberland County Employees' Retirement Fund. Wife's waiver of any claim or interest she may have in Husband's retirement account as set forth herein is conditioned upon Husband's payment of all credit card debt assumed by Husband in paragraph 11 of this Marriage Settlement Agreement. Should Husband failto pay in full all credit card debt otherwise assumed by him under the terms of this agreement or discharge or attempt to discharge any or all of said credit card debt and/or the obligation to Wife for indemnification as set forth in paragraph 11 through bankruptcy Wife shall be entitled to pursue any rights she might have in Husband's retirement plan in accordance with Pennsylvania law through a court of competent jurisdiction. The parties hereto agree that the Court of Common Pleas of Cumberland County, Pennsylvania shall retain jurisdiction subsequent to the obtaining of a divorce and until such time as all credit card debt as referred to herein is paid in full by Husband for the purpose of determining any interest Wife may have in Husband's retirement plan through the Cumberland County Employees' Retirement Fund should Husband fail to pay the credit card debt in accordance with this agreement. 14. Except as otherwise specifically provided for herein each of the parties hereto specifically waives any and all right they may have at present or hereinafter may have for \, _., ~T- 7 spousal support and each further waives any and all right they may have at present or hereafter may have for alimony, alimony pendente lite, or separate maintenance and support as provided in Section 3701 and 3702 of the Divorce Code. 15. Each party shall be individually responsible for the payment of his or her own respective attorney's fees and costs, both for the negotiation and preparation of this Agreement and also for any divorce action which may be filed. 16. Except for any debt or obligation of either party to the other under this Agreement, each party hereby agrees to save and hold the other harmless from all personal debts and obligations incurred by him or her from the date hereof. 17. Each party represents and warrants to the other that he or she has not incurred any debt, obligation or other liability other than described in this Agreement on which the other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereinafter instituted seeking to hold the other party liable for any other debts, obligations, liability, act or omission of such party, such party will, at his or her sole expense, defend the other against any such claim or demand, whether or not well-founded, and that he or she will indemnify and hold harmless the other party in respect to all damages resulting therefrom. Each party hereby releases the other from all claims, liabilities, debts, obligations, actions and causes of action of every kind that have been or will be incurred relating to or arising from the marriage between the parties. However, neither party is relieved or discharged from any obligation under this Agreement, or under any instrument or document executed pursuant to this Agreement. ~ I 8 18. Neither party shall contract any debt or liability for which the other party or his or her property or estate might be responsible, and shall indemnify and save the other harmless from any and all claims and demands made against him or her by reason of the debts or obligations incurred by the other party. 19. If either party breaches any provisions of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other renledies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of reasonable legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. 20. Each party acknowledges that he or she has received independent legal advice from counsel of his or her selection, and each fully understands the facts and has been fully. informed as to his or her legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that the execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any collusion or improper or illegal agreements. 21. Each of the parties shall, from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments which may be reasonably required to give full force and effect to the provisions of this Agreement. 22. It is understood and agreed by the parties hereto that Wife has filed an action in divorce in the Court of Common Pleas of Cumberland. County in which she will alleged that the marriage is irretrievable broken under Section 3301(c) and/or Section 3301(d) of the '''~ ~'I I 9 Divorce Code. Both parties further understand and agree that they will execute and file promptly when due any affidavits of consent which may be necessary and all other petitions and documents necessary to effectuate the divorce. 23. A modification or waiver of any of the provisions of this Agreement 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 the 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. 24. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 25. If any term, condition or clause or provision of this 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, operation and effect. 26. This Agreement shall be binding and shall inure to the benefit of the parties hereto and to their respective heirs, executors, administrators, successors and assigns. :--~Il;. " I I~ I i I ~ . 10 IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above written. WITNESS: tJ;~ .... oZ. XOOllOmt:.vk- Wilma L. Keeseman .,~as4. -A.1t~ L #n'~ Ricky ~. Keeseman (SEAL) (SEAL) COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) On this, the / f?" day of July, 2000, before me, the undersigned officer, personally appeared WILMA L. KEESEMAN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. NOTARIAL SEAL SHELLY SEXTON. NOTARY PUBLIC CARLISLE BORO. CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 26, 2003 Member, Pennsylvania Association of Notaries ) COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) On this, the 1S- day of July, 2000, before me, the undersigned officer, personally appeared RICKY L. KEESEMAN, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. (SEAL) Notarial Seal j Jennifer S. Lindsay. Notary Public Carlisle Boro, Cumberland County My Commission Expires Nov. 29. 2003 Member, PennsylvaniaAssociallon otNn\".r':~" ,. -", II "'~ "".\IlI'\lllllllll!'~,<lI .~ ." 1Ill!, ''''~''''''''''''''~~~ _.- i . _, ,,;,._ " .~ , ",,",~ W~M'_ . -r-'L"" ~l-__~L__ ~--,~ j--: ~ --;:.: - ~- ~-: i - )>~~ L~_ -~1 -< "'0_ (') C~ ~,. ---' "'1IIIiJ (::) . -~ -TI C-.o) (.n ~ ~II!lII!II!I!lI~~"'1W"""_~B"Jfi'#i'-ir.""1i';>~")W1~'i\Ul'!HIi!"'~~I1II!Ifff,1!~n!m:!~_~I"l"lI"'I!Ili~~i'n"""t/i1l!iJI'I'I~W# Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA WILMA L. KEESEMAN, v. : CIVIL ACTION - LAW Defendant : NO. 2000-2125 : IN DIVORCE CIVIL TERM RICKY L. KEESEMAN, 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: April 8 2000 bv restriced delivery certified mail. return receitlt requested 3. (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff Julv 18 2000 ; by Defendant July 12. 2000 4. Related claims pending: The Marriage Settlement Agreement dated July 18. 2000 is inCOl:porated herein by reference. but is not merged into the Decree in Divorce. The Court retains and/or reserves iurisidiction over this matter in accordance with said AIlTeement and soecifically 1;>arallraph 13 thereof. 5. Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: Julv 31 2000 Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: Julv 31 2000 Date: July #-' 2000 By: Ronald E. Jo n, Esq. 78 West Po f t Street Carlisle, P 17013 (717) 243-0123 Supreme Court ID No. 16453 --""'"-,,,," ~I ,-, ',,-,,,- (') ~~ ::::.:: i:Jr;._ rr;r-;' ;:;;~:: 6:~~. ~C ~2~ <-, ,-'--' -< ~.,,1 :::; ~ ""'''''''''"''''''''''_~~ ~,I:gl!i@llI~~f.IIJ'i!",~~~ ,~~~~~~ ~ ,~, __~~Ji!~IfI'!!'\!IiJ~fijfl~'~W'''''-'''',_"",!!,.....;\'-,;>r,lm'~~~i'!>I''<j."~ii>\Hl''-'fi''~''''''1"'T'"~"~~'>'F.!"i!Pi'\""J,"'rn~';&:'!;-~~M\ll~~_\1I~'JI'ilW"lIfR!lmlJ!f.ll1 WILMA L. KEESEMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Defendant : CIVIL ACTION - LAW . ,/ : NO. t>-O . ;2/.;2.5 CIVIL TERM : IN DIVORCE v. RICKY L. KEESEMAN, NOTICE 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, High and Hanover Streets, Carlisle. 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 Phone: (717) 249-3166 :-" ~ 1"' . II'" '-",' ,r. WILMA L. KEESEMAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW RICKY L. KEESEMAN, Defendant : NO. ()-tJ - ,),/.;25 CIVIL TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Wilma L. Keeseman, who currently resides at 101 Game Land Road, Newville, Cumberland County, Pennsylvania, since November, 1982. 2. Defendant is Ricky L. Keeseman, who currently resides at 101 Game Land Road, Newville, Cumberland County, Pennsylvania, since November, 1982. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on November 14, 1982, at Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. 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. " ~~~ ~"' I verify that the statements made in this Complaint 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. Date: L.j /-1 ~6 ;; J,L~Jlb.A~~ Wilma L. Keeseman, Plaintiff ANDREWS & JOHNSON Ronald E. 10 Attorneys for 78 W. Pomfr Street Carlisle, PA 17013 (717) 243-0123 i- ~_ , ._1 1-1- Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA WILMA L. KEESEMAN, v. : CIVIL ACTION - LAW RICKY L. KEESEMAN, Defendant : NO. 2000-2125 : IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was fIled on April 7,2000. 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 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 Pal C.S. 9 4904, relating to unsworn falsification to authorities. Date: ~QfoO !,1;LrI...1oo),o;m;;.--. / Wilma L. Keeseman, Plaintiff " .,'1 /' 'I !1, - ~ ,~~ _. ~~"U_, () c." -z;r~~ rni~( 2:T:" 6i~:~,: -< ....:~' r:: c> ~ ~8; -'~ z =2 "" .~" .~ ~~ '"-' o ,"~, , , ,~ . C...0 ,.,' ~. (Ji IIlftIllJIr - "M"''',~ rm ,.""_..~." <, ,~"f{""",.",,"f>.l;I"'l1'~.._....~,,_:I!!\!;!l!JII!!'-"~Q!II,~~I~~( Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA WILMA L. KEESEMAN, v. : CIVIL ACTION - LAW Defendant : NO. 2000-2125 : IN DIVORCE CIVIL TERM RICKY L. KEESEMAN, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 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. ~4904, relating to unsworn falsification to authorities. Date: 7/;fa I i(L d, )(00 ^ cmw-..... Wilma L. Keeseman, Plaintiff . - -~-, ~ ~~~ ~ - ~ . ~ ~, 1"""'" ". .- ~ ~~, "" ~ '4 ._ -. - ,- "-~_. .'~ .~- ~ n~ '^- _", () -0 f;: In, C--' - fJ:' ~.:r" ~C. (/) > ~f!! >r~, 2:(~-; -\~ .~ c) ('..:) ,-....., ~i I~ J:-'::::: c..., ~- '-. - (..J'l _.~__~~.I!l'l!"<~!I"1R~O~"!9iRW"'1~~ffl'~'!I!lIll'11lllfll~~~~!llJlW'i''1II!lPf!!nIir;;1 WILMA L. KEESEMAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNNSYLVANIA v. CIVIL ACTION - LAW RICKY L. KEESEMAN, Defendant NO. 00-2125 IN DIVORCE CIVIL TERM 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 April 7, 2000. 2. Defendant acknowledges receipt and accepts service of the Complaint on April 8, 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. , I 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 I understand that I may request that the court require counseling. I do not request that I, the court require counseling. I! I' II !i !', 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: 1- /!A . ,}.oM ~;/'1~ ICKY L. KEESEMAN *1 ~"'"""'" .. 11,_- .~'O . " ~. .. -- '- .'," , ~~-. ,," 0 ~ ,-...., C. ,~ " "$:: '> s.; ""-'~ ITi Z , L W 0) -< c:-: c: <' r,~ .- Z (~~; 5> c: ,~ :~ -en ~, " '-~,-",- ""-. " ''''''-"''.... . ,'" ", ," '~ ,.,1-" ~'"r -rl1llllill1!li~~~~~JI~~!I'illI!ll\lll!l!~I~~.-~""""",,,,,,,,,'f'!"'l ~~ i i i I I I I I" , WILMA L. KEESEMAN, Plaintiff v. RICKY L. KEESEMAN, Defendant , : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. aOCO- ald.5 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 10th day of April, 2000, 1996, I, Ronald E. Johnson, Esquire, attorney for Wilma L. Keeseman, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above-captioned matter, upon the Defendant at his residence at 101 Game Land Road, Newville, Pennsylvania, 17013, by depositing the same in the U.S. Mail, postage prepaid, certified, , deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on April 8, 2000, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. Sworn and subscribed to before me this 10th day of April, 2000. NORLEAL SHELLY SEXTON. ARY PUBLIC CARLISLE BORO, CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 26, 2003 Member, Pennsylvania M7"I';ntion of Notaries I' ANDREWS & JOHNSON By: - SENDER: --- ________M__'___..~_~__._~ I also wish to receive the follow- ing services (for an extra fee): o Complete items 1 aod/or 2 for additional services. Complete items 3, 4a, and 4b. [1,':'rint your name and address on the reverse of this form so thai we can return this card to you. o Attach this form 10 the front of the rnailpiece, or on the back jf space does not permit. C:Write 'Return Receipt Requested" on the mailpiece below the article number. othe Return Receipt win show to whom the article was delivered and the date deJjvered~ 3. Article Addressed to: Ricky L. Keeseman 101 Game Land Road Newville, PA 17241 L f(u.:,LfVlOlrr\ By: (Print Name) ~.~ (ijqdressee o[Agent) : ; i i ~': I, ., PS Form 3811, December 1994 1. 0 Addressee's Address 4a. Article Number Z 338 759 615 4b. Service Type o Registered o Express Mail iI Return Receipt for Merchandise 7. 0"01 Delivery q - -ty & 8. Addressee's Address (Only if requested and fee is paid) ErCertified o Insured DCOD ai " 'S; l; !IJ Q. 'il ~ II: c ~ " ';j II: Dl, C '(;j' " l! " o ... ... c .. t: 1025~5-99-B_0223 DOmestic Return Receipt Exhibit A II 1Il"l"I, --~=~"," -'"~, "~\9,~_"_, [7'J.1"'F._~'... ~ . ,,-," _. ~ ,~, .' <" ~"~- ~,~ ^" ~~< -" ""~'ta 0 = ~ C 0 s: :r~'" -0\.)::: -U rnrTl ;XJ Z:u zs;: .(:'" u:> . -<Z ~O -U ..,.--.. :"': ::' -, 55 -< ~< " ~~ ~",."U~if,II'1~'!iIlIl!'@~""'~"'I'W<~~~"fj/"'i':'!!iffM9'>jII'R'1f?~~_~'!'~'I'll!ll>"'__~I~''I!!I\ll'\11l!1ro;l.