HomeMy WebLinkAbout07-0727
Renee Keyes, )
Plaintiff )
V. )
Michael Keyes, )
Defendant )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 1),7-17,27 CIVIL
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.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES
OR EXPENSES BEFORE A DIVORCE 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, Pennsylvania 17013
(717) 249-3166
i
Renee Keyes, )
)
Plaintiff
V. )
Michael Keyes, )
Defendant )
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 0 7--U:7 CIVIL
IN DIVORCE
NOTICE REGARDING THE AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding filed in the
Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance
with Section 3302(d) of the Divorce Code, you may request that the court require you and your
spouse to attend marriage counseling prior to a divorce being handed down by the court. A list
of professional marriage counselors is available at the Domestic Relations Office, 13 North
Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to
you and you are not bound to choose a counselor from this list. All necessary arrangements and
the cost of counseling sessions are to be bome by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling within twenty
(20) days of the date you receive this notice. Failure to do so will constitute a waiver of your
right to request counseling.
a
Prepared by:
DAN REGAN
ATTORNEY AT LAW
1300 MARKET ST., SUITE 1
LEMOYNE, PA 17043
(717) 737-4433
DAN_REGAN@C OMCAST.NET
Renee Keyes,
Plaintiff
V.
Michael Keyes,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. Z),7- y.? 7 CIVIL
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff is Renee Keyes, who has been residing at 2213 Brigade Road, Enola,
Cumberland County, Pennsylvania, since August 2006.
2. Defendant is Michael Keyes, who has been residing at 25 Morris Road,
Duncannon, Perry County, Pennsylvania, since at least 2002. Defendant's mailing address is 25
Morris Road, Duncannon, Pennsylvania 17020.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for
at least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on December 10, 2005, in Stowe, Vermont.
5. There have been no prior actions of divorce or annulment between Plaintiff and
Defendant.
6. Defendant is not a member of the Armed Forces of the United States of America
or any of its Allies.
Count One: Request for Divorce under Section 3301(c) of the Divorce Code
7. Paragraphs 1 through 6 of this Complaint are incorporated herein by reference
hereto.
8. The marriage between Plaintiff and Defendant is irretrievably broken.
9. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the Court require Plaintiff and Defendant to participate in counseling.
WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce
pursuant to 25 Pa.C.S. § 3301(c).
Count Two: Request for Divorce under Section 3301(d) of the Divorce Code
10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference
hereto.
11. The Plaintiff and the Defendant have been living separately and apart. At a
subsequent time, Plaintiff may submit an Affidavit that the parties have been living separately
and apart for at least two (2) years.
WHEREFORE, upon submitting the affidavit referenced in Paragraph 11 above, Plaintiff
respectfully requests the Court to enter a decree of divorce pursuant to 25 Pa.C.S. § 3301(d).
Respectfully submitted,
DAN REGAN
Pa. Lic. No. 72461
1300 Market Street, Suite 1
Lemoyne, PA 17043
(717) 737-4433
Dated: February 7, 2007
-2 -
VERIFICATION
verify that the statements made in this Complaint are true and correct. I understand that
false statements made herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating
to unsworn falsification to authorities.
Dated: ?Juj r
Renee Keyes, PI ' tiff
-3 -
Renee Keyes,
Plaintiff
V.
Michael Keyes,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. CIVIL
IN DIVORCE
CERTIFICATE OF SERVICE
I, Dan Regan, certify that I have this day served a true and correct copy of the
foregoing Complaint via certified mail with return receipt requested and restricted
delivery, and a second copy of the foregoing Complaint via first class mail, each
addressed as follows, upon:
Michael Keyes
25 Morris Road
Duncannon, PA 17020
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DAN REGAN
Pa. Lic. No. 72461
1300 Market Street, Suite 1
Lemoyne, PA 17043
(717) 737-4433
Dated: February 7, 2007
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Prepared by:
DAN REGAN
ATTORNEY AT LAW
1300 MARKET ST., SUITE 1
LEMOYNE, PA 17043
(717) 737-4433
DAN_REGAN@C OMCAST.NET
Renee Keyes,
Plaintiff
V.
Michael Keyes,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 07-01,727 CIVIL
IN DIVORCE
AFFIDAVIT OF RETURN OF SERVICE UPON DEFENDANT, MICHAEL KEYES,
BY MAIL PURSUANT TO PA. R.C.P. 405(c)
Dan Regan, being duly swom according to law, deposes and says that:
On February 7, 2007, a true copy of the "Complaint under Section 3301(c) of the
Divorce Code" was mailed to Defendant, Michael Keyes, at his address by certified mail, return
receipt requested. On February 26, 2007, the post office returned the letter, attached hereto as
Exhibit 'A" stamped with the notation that the letter was unclaimed.
2. On February 7, 2007, a true copy of the "Complaint under Section 3301(c) of the
Divorce Code" was mailed by ordinary mail to Defendant, Michael Keyes, at his address, with
the deponent's return address appearing on the envelope. It has been more than fifteen days
since this mailing and the letter has not been returned.
Dated: Dan Regan
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
BEFORE ME, A NOTARY PUBLIC, THIS 01 DAY OF MARCH, 2007, PERSONALLY APPEARED DAN REGAN, KNOWN TO BE
(OR SATISFACTORILY PROVEN) TO BE THE PERSON WHOSE NAME IS SUBSCRIBED TO THE FOREGOING "AFFIDAVIT ClF?2ETURN
OF SERVICE" AND ACKNOWLEDGED THAT HE EXECUTED THE SAME FOR THE PURPOSES THEREIN CON Ji
IN WITNESS WHEREOF, I HAVE HEREUNTO SET ME HAND AND SEAL.
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Allison E. Kapp, Notary Public
East Pennsboro Twp., Cumberland County
My Commission Expires Oct. 21, 2009
Member, Pennsylvania Association of Notaries
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Renee Keyes,
Plaintiff
V.
Michael Keyes,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
No. 07-0727 CIVIL
IN DIVORCE
CERTIFICATE OF SERVICE
I, Dan Regan, certify that I have this day served a true and correct copy of the
foregoing document by first class mail, addressed as follows, upon:
Michael Keyes
25 Morris Road
Duncannon, PA 17020
- 4-exs.-
DAN REGAN
Pa. Lic. No. 72461
1300 Market Street, Suite 1
Lemoyne, PA 17043
(717) 737-4433
Counsel for Renee Keyes, Plaintiff
Dated: March 9, 2007
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RENEE KEYES,
Plaintiff
VS.
MICHAEL KEYES,
Defendant
§ IN THE COURT OF COMMON PLEAS OF
§ CUMBERLAND COUNTY, PENNSYLVANIA
§
§ NO. 07-0727 CIVIL
§
§ CIVIL ACTION - LAW
§ IN DIVORCE
SUBSTITUTION OF COUNSEL WITHOUT LEAVE OF COURT PURSUANT TO RULE
1012(b)(2)(ii)
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, Renee Keyes.
I hereby certify that this change is not intended to, nor will it, delay this proceeding to the best of my
knowledge, information and belief.
Papers may be served at the address set forth below.
Tabetha A. Tanner, Esquire
I.D. No.: 91979
Tanner Law Offices, LLC
1300 Market Street, Suite 10
Lemoyne, PA 17043
(717) 731-8114
Date: $t&?. 4- -1a, n,?
Tabetha A. Tanner, Esquire
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PRAECIPE FOR WITHDRAWAL OF APPEARANCE ° C
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TO THE PROTHONOTARY:
Please withdraw my appearance on behalf of the laintiff, Renee Keyes.
Date: t - i S a $
Da Regan, Esquire rn
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RENEE M. KEYES,
Plaintiff/Counter-Defendant
V.
MICHAEL KEYES,
Defendant/Counter-Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY
PENNSYLVANIA
No. 0-1 , 0-7a-7
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S COUNTERCLAIM
AND NOW, this(, dayof2008, comes the Defendant/Counter-Plaintiff,
MICHAEL KEYES, pro se, and files this Counterclaim and avers as follows:
RENEE M. KEYES, Plaintiff/Counter-Defendant is directed to answer the following
counterclaim within twenty (20) days from the date of service hereof, or suffer possible default.
COUNTI
REQUEST FOR ALIMONY PENDENTE LITE AND ALIMONY
1) Defendant/Counter-Plaintiff is unable to sustain himself during the course of
litigation.
2) Defendant/Counter-Plaintiff lacks sufficient property to provide for his reasonable
needs and is unable to adequately sustain himself in a reasonable manner.
3) Defendant/Counter-Plaintiff requires reasonable support to adequately maintain
himself.
4) PlaintifflCounter-Defendant has a substantial income and can afford to maintain
living arrangements.
5) Defendant/Counter-Plaintiff requests the Court to preserve his right to seek an
award of reasonable alimony pendente lite, counsel fees, costs and expenses and to order such
additional sums thereafter as may deemed necessary and appropriate.
WHEREFORE, Defendant/Counter-Plaintiff respectfully requests the Court to enter an
award of alimony pendente lite until final hearing and thereupon to enter an Order of Alimony in
her favor, pursuant to the Divorce Code.
Respectfully submitted
B ?
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HAEL KEYES
25 Morris Road
Duncannon, PA 17020
Defendant/Counter-Plaintiff
Date: 0 O,' 2008
2
s
VERIFICATION
I, MICHAEL KEYES, VERIFY THAT THE STATEMENTS MADE IN THE
FOREGOING COUNTERCLAIM ARE TRUE AND CORRECT TO THE BEST OF MY
KNOWLEDGE, BELIEF AND INFORMATION AND THAT THE DOCUMENT IS
SUBMITTED IN GOOD FAITH. I UNDERSTAND THAT FALSE STATEMENTS HEREIN
ARE MADE SUBJECT TO THE PENALTIES OF 18 PACS §4904 RELATING TO
UNSWORN FALSIFICATION TO AUTHORITIES AND THAT THE COURT MAY IMPOSE
AN APPROPRIATE SANCTION FOR A BAD FAITH VIOLATION.
(SEAL)
MIC L KEYES
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Date: 4 2008
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RENEE M. KEYES, IN THE COURT OF COMMON PLEAS
Plaintiff/Counter-Defendant CUMBERLAND COUNTY
PENNSYLVANIA
V. No. O 7 - O-7 X7
MICHAEL KEYES, CIVIL ACTION - LAW
Defendant/Counter-Plaintiff IN DIVORCE
• CERTIFICATE OF SERVICE
I, Michael Keyes, pro se, hereby certify that I served a true and correct copy of the
Defendant's Counterclaim to Plaintiff's Complaint by depositing same in the United States Mail,
Harrisburg, Pennsylvania, by regular first class mail, postage prepaid, addressed as follows:
Renee M. Keyes
2213 Brigade Road
Enola, PA 17025
Plaintiff/Counter-Defendant
Respectfully submitte l
By: I
MIC AEL KEYES
25 Morris Road
Duncannon, PA 17020
Defendant/Counter-Plaintiff
Date: O -4' . 2008
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TANNER LAW OFFICES, LLC
1300 Market Street, Suite 10
Lemoyne, PA 17043
Telephone: (717) 731-8114
Facsimile: (717) 731-8115
RENEE KEYES, § IN THE COURT OF COMMON PLEAS OF
Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA
V. § NO. 07-0727 CIVIL
MICHAEL KEYES, § CIVIL ACTION - DIVORCE
Defendant §
NOTICE
If you wish to deny any of the statements set forth in this affidavit, you must file a counter-
affidavit within twenty days after this affidavit has been served on you or the statements will be
admitted.
AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on July 27, 2006 and have continued to live separate
and apart for a period of at least two (2) years.
2. The marriage is irretrievably broken.
3. 1 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.
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: IL M?Li ??
Renee Keyes, aintiff
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RENEE KEYES, § IN THE COURT OF COMMON PLEAS OF
Plaintiff § CUMBERLAND COUNTY, PENNSYLVANIA
V. § NO. 07-0727 CIVIL
MICHAEL KEYES, § CIVIL ACTION - DIVORCE
Defendant §
NOTICE OF INTENTION TO REQUEST ENTRY OF
§ 3301(d) DIVORCE DECREE
TO: MICHAEL KEYES, Defendant
You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-
affidavit to the affidavit. Therefore, on or after October 6, 2008, the other party can request the court to enter
a final decree in divorce.
If you do not file with the prothonotary of the court an answer with your signature notarized or verified
or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which
you may file with the prothonotary of the court is attached to this notice.
Unless you have already filed with the court a written claim for economic relief, you must do so by the
above date or the court may grant the divorce and you will lose forever the right to ask for economic relief.
The filing of the counter-affidavit alone does not protect your economic claims.
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
32 Bedford Street
Carlisle, PA 17013
(717) 249-3166
RENEE KEYES, §
plaintiff §
V. §
MICHAEL KEYES, §
Defendant §
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-0727 CIVIL
CIVIL ACTION - DIVORCE
NOTICE
IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE
AND YOU DO NOT WISH TO MADE ANY CLAIM FOR ECONOMIC RELIEF,
YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT.
COUNTER-AFFIDAVIT
UNDER SECTION 330I(d) OF THE DIVORCE CODE
1. Check either a or b:
a. I do not oppose the entry of a divorce decree.
b. I oppose the entry of a divorce decree.
If you oppose entry of a divorce decree, check i, ii, or both:
i. The parties to this action have not lived separate and
apart for a period of at least two years.
ii. The marriage is not irretrievably broken.
2. Check either a or b:
a. I do not wish to make any claims for economic relief. 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.
b. I wish to claim economic relief which may include alimony, division of
property, lawyer's fees or expenses or other important rights.
I understand that, in addition to checking (b) above, I must also file all
of my economic claims with the prothonotary in writing and serve them
on the other party. If I fail to do so before the date set forth on the
Notice of Intention to Request Divorce Decree, the divorce decree may
be entered without further delay.
I verify that the statements made in this affidavit are true and correct to the best of my
knowledge, information and belief. I understand that false statements made herein may
subject me to penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to
authorities.
Date:
Michael Keyes, Defendant
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RENEE KEYES, § IN THE COURT OF COMMON PLEAS OF
Plaintiff § CUMBERLAND COUNTY,
PENNSYLVANIA
",
Sj
V. § NO. 07-0727 CIVIL
MICHAEL KEYES, § CIVIL ACTION - DIVORCE
Defendant §
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I served a copy of the Affidavit Under Section §3301(d)
of the Divorce Code filed in the above-captioned matter upon upon the Defedant, Michael
Keyes, by certified U.S. mail, restricted delivery, return receipt requested, addressed as
follows:
Mr. Michael Keyes
25 Morris Road
Duncannon, PA 17020
and did thereafter receive same as evidenced by the attached Post Office receipt card dated
August 26, 2008.
io/7/0g tea" /? ;;rMoo
Date Tabetha A. Tanner, Esquire
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¦ Complete items 1, 2, and 3. Also complete
Item 4 if Reshicfied Delivery is desired.
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so Mat we can reWm the card to you.
¦ Attach this card to the back of the mailplece,
or on the front N space permits.
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Tanner Law Offices, LLC
1300 Market Street, Suite 6
Lemoyne, PA 17043
Telephone (717) 731-8114
Fax(717)731-8114
RENEE KEYES, §
Plaintiff §
V. §
MICHAEL KEYES, §
Defendant §
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-0727 CIVIL
CIVIL ACTION - DIVORCE
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I served a copy of the Notice of Intention to Request Entry
of a §3301(d) Divorce, filed in the above-captioned matter, upon the Defendant, Michael
Keyes, by Priority U.S. mail, delivery confirmation, addressed as follows:
Mr. Michael Keyes
25 Morris Road
Duncannon, PA 17020
Delivery was confirmed by the U.S. Postal Service on September 17, 2008 as
evidenced by the attached U.S. Postal Service Track and Confirm printout.
Respectfully submitted,
_Iae4?4 d x_k/wtan,
Tabetha A. Tanner, Esquire
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Detailed Results:
• Delivered, September 17,2008,12:52 pm, DUNCANNON, PA 17020
• Arrival at Unit, September 17, 2008, 7:11 am, DUNCANNON, PA
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• Processed, September 16, 2008, 10:14 pm, SWEDESBORO, NJ
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• Acceptance, September 15, 2008, 5:18 pm, CAMP HILL, PA 17011
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Tanner Law Offices, LLC
1300 Market Street, Suite 10
Lemoyne, PA 17043
Phone (717) 731-8114/Fax (717) 731-8115
ttanner@tanner-law.com
RENEE KEYES, §
Plaintiff §
V. §
MICHAEL KEYES, §
Defendant §
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 07-0727 CIVIL
CIVIL ACTION - DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Please transmit the record, together with the following information, to the court for
entry of a divorce decree:
1. Ground for Divorce: irretrievable breakdown and 2 year separation under
Section 3301(d) of the Divorce Code.
2. Date and Manner of Service of the Complaint: Certified Mail, Restricted
Delivery sent on February 7, 2008 was unclaimed. First Class Mail on
February 7, 2008 was not returned within 15 days, thus service was effected
on February 22, 2008 pursuant to Pa.R.C.P. 1930.41(c)(1).
3. Date of Execution of the Affidavit Required by Section 3301(d) of the Divorce
Code: by Plaintiff on August 7, 2008.
4. Related Claims Pending: No other marital claims pending.
5. Date of Manner of Service of the Notice of Intention to Request Entry of a
3301(d) Divorce Decree: Priority U.S. Mail, delivery confirmation,delivery
confirmed by U.S. Postal Service, dated September 17, 2008.
Respectfully Submitted,
Tabetha A. Tanner, Esquire
Attorney for Plaintiff
Supreme Court I.D. No. 91979
TANNER LAW OFFICES, LLC
1300 Market Street, Suite 10
Lemoyne, PA 17043
(717) 731-8114
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IN THE COURT OF COMMON PLEAS
Plaintiff
OF CUMBERLAND COUNTY
STATE OF PENNA.
No. 07-0727 Civi I
VERSUS
MICHAEL KEYES,
De:Vendant
DECREE IN
DIVORCE
AND NOW,
0"1;sft / Y
OwTor*14 044 •
SR -, IT IS ORDERED AND
DECREED THAT Renee Ke yes PLAINTIFF,
AND Michael Ke yes 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;
None.
ATTEST. J.
Aire
PROTHONOTARY
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