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MARITAL SETTLEMENT AGREEMENT
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TillS AGREEMENT, made this r-1 day of -.I-I:' I fl ,(, I ) ,2000, is by and
between BEVERLY ANN KEISTER, of Carlisle, Pennsylvania, hereinafter referred to as "Wife,"
and RICHARD E. KEISTER, of Harrisburg, Dauphin County, Pennsylvania, hereinafter referred
to as "Husband,"
WITNESSETH:
WHEREAS, the parties hereto were married on February 26, 1988, in Cumberland County,
Pennsylvania; there were no children born of the marriage; and
WHEREAS, certain unhappy and irreconcilable differences have arisen between the parties;
as a result, Husband filed a divorce action in the Court of Common Pleas of Cumberland County,
Pennsylvania, to Docket No. 97-3585 Civil Term; and
WHEREAS, diverse and unhappy differences, disputes and diniculties have arisen between
the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their
natural lives, and the parties hereto are desirous of settling fully and finally their respective financial
and property rights and obligations as between them relating to the ownership and equitable
distribution of real and personal property; the settling of all matters between them relating to the past,
present and future spousal support, alimony and/or maintenance of Wife by Husband or Husband by
Wife; and in general, the settling of any and all claims and possible claims by one againstlhe other
or against their respective estates; and
WHEREAS. the parties hereto have been fully, separately, and independently appraised and
advised of their legal rights, remedies, privileges. and obligations arising out of the marriage
relationship, or otherwise, by counsel of their own choice and selection, the Wife, being represented
by Marilyn C. ZiIIi, Esquire, of the Law Offices of Fetterhoff and Zilli, and the Husband being
represented by Debra Denison Cantor, Esquire of the Law Offices ofReager, Adler & Cognelli, P.C,;
and
WHEREAS, both parties have made independent inquiry and investigation with respect to
their respective legal rights, remedies, privileges, and obligations, arising out of the marriage, or
otherwise, and each has been fully informed of the other's assets, property, holding, income and
prospects; and
WHEREAS, the parties hereto each warrant and represent to the other that they each fully
understand all the terms, covenants, conditions, provisions, and obligations incumbent upon each of
them by virtue of this Agreement to be performed or contemplated by each of them hereunder, and
each respective individual's best interest of each, and not the result of any fraud, duress, or undue
influence exercised by either party upon the other or by any other person or persons upon either.
NOW, THEREFORE, the recitals set forth hereinabove, being incorporated by reference
herein, and deemed an essential part hereof. and further consideration of the promises contained
within this Agreement, the parties hereto intending to be legally bound, mutually agree as follows:
I. PERSON A L RIGHTS: Wife and husband may and shall, at all times hereinafter,live
separate and apart. Each shall be free from all control, restraint, interference or authority, direct or
indirect, by the other in all respects as fully as ifshe or he were unmarried. Each may reside at such
place or places as she or he may select Each may, for her or his separate use or benefit, conduct,
2
carry on and engage in any business, occupation, profession or employment which to her or him may
deem advisable. This provision shall not be taken, however, to be an admission on the part of either
Wife or Husband of the lawfulness of the causes which led to, or resulted in the continuation of their
living apart. Wife and Husband shall not molest, harass, disturb, or malign each other or their
respective families, nor compel or attempt to compel the other to cohabit or dwell by any means or
in any manner whatsoever with her or him.
2. FULL DISCLOSURE: The parties hereby acknowledge and agree that each of them
has made to the other a true, full, and complete disclosure of all property and interests which either
or both ofthem have in all marital and separate property as defined by the Pennsylvania Divorce Code
and they do hereby waive an inventory of said property.
3. MUTUAL RELEASE: Wife and Husband each do hereby mutually remise, release,
quit claim and forever discharge the other and the estate of each other, for all time to come, and for
all purposes whatsoever, of and from any and all rights, titles, and interests, or claims in or against
the property (including income and gain from property hereafter accruing) of the other or against the
estate of each other, of whatsoever nature and whatsoever situate, which she or he now has or at any
time hereafter may have against each other, the estate of each other or any part thereof, whether
arising out of any former acts, contracts, engagements or liabilities of each other or by way of dower
or courtesy, or claims in the nature of dower or courtesy of widow's or widower's rights, family
exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's
3
will, or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a
surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a)
Pennsylvania, (b) any State, Commonwealth or Territory of the United States, or (c) any other
country. Both parties waive the right which either may have or at any time hereafter have for past,
present, or future spousal support or maintenance, alimony, alimony pendente lite, costs or expenses,
whether arising as a result of the marital relation, or otherwise, except, and only except, all rights and
agreements and obligations of whatsoever nature arising or which may arise under this Agreement
(see Paragraphs 4.e. and 6.c., infra) or for the breach of any part thereof. It is the intention of Wife
and Husband to give to each other, by the execution of this Agreement, a full, complete and general
release with respect to any and all property of any kind or nature, real, personal or mixed, which the
other now owns or may hereafter acquire, except and only except all rights and agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or for the breach
of any part thereof. subject, however, to the implementation and satisfaction of the conditions
precedent as set forth herein.
4. ASSETS: The parties agree that their marital assets consist of the following:
a. miscellaneous personal property;
b. miscellaneous boats, waverunners;
c. motorhome with an appraised value of$25,OOO.00;
d. increase in value of the home at 25113 Wymont Park Road, Worton,
Maryland, or $45,000.00;
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e. the present value of the ]00% survivor annuity benefit of Husband's
Central Pennsylvania Teamsters Pension Fund, or $17,459.00.
5. DEBT: Both parties represent and warrant to the other party that they have not
incurred any debts to which the other, or the estate of the other may be held liable since their
separation except as provided herein, and that except only for the rights arising out of this Agreement,
neither party has incurred or will hereafter incur any liability whatsoever for which the other party or
the estate of the other party will be or could be liable.
Husband and wife agree that should any debt or liability be incurred or have been incurred by
one party, since their separation, that party acknowledges that such debt is the sole responsibility of
the person who incurred that debt and any and all claims made against the other on account of such
debt may be deducted from the share to which the person incurring the debt is entitled as the result
of this Agreement.
The parties agree that their debt consists of the following:
a. the balance due on a loan on the motorhome, or $22,000.00;
b. the balance due on a Sears charge card, or $544.00;
c. the balance due on a Discover One credit card, or $3,936.00;
d. the balance due on a Capitol One credit card, or $600.00;
e. the balance due on a Members First credit card, or $5,000.00.
Husband agrees to be solely responsible for payment of all of the above-noted debt, to require no
payment from Wife on any of these accounts and to indemnify and hold Wife harmless on the entirety
5
of this debt.
6. DIVISION OF PROPERTY,
a. Personal Prooertv: The parties hereto mutually agree that elTective upon the
signing of this Agreement, they have elTected a satisfactory division of the furniture, household
furnishings, appliances, personal elTects, clothing, jewelry, and all other household and personal
property between them and they mutually agree that each party shall, from and after the date hereof,
be the sole and separate owner of all such tangible personal property presently in his or her
possession, whether said property was heretofore owned jointly or individually by the parties hereof,
and this Agreement shall have the elTect of an assignment or receipt from each party to the other for
such property as may be in the individual possession of each of the parties hereto, the elTective date
of said bill of sale to be contemporaneous with the date of the execution of this Agreement. As of
the elTective date of this Agreement, each party shall own, have, and enjoy independently of any claim
or right of the other, all items received as per this Agreement, with full power to dispose of same as
fully and elTectively in all respects and for all purposes as ifhe or she were unmarried.
b. Motorhome. miscellaneous Boats. waverunners: The parties agree that
Husband shall become the sole and exclusive owner of the motorhome (subject to the debt remaining
to be paid thereon) and of the miscellaneous boats and waverunners. Wife agrees to execute all
documents necessary to elTectuate such transfer to Husband's sole and exclusive ownership, as per
paragraph 14, infra, of this Agreement.
c. Survivor Benefit: The parties agree that the survivor annuity benefit of$450.00
6
per month shall be paid to Wife; Husband agrees that he shall not change the beneficiary of this
annuity and that it shall be paid to Wife, upon his death, in accordance with all provisions of the
Central Pennsylvania Teamster's Pension Fund Plan. Husband agrees to provide proofupon demand
of Wife's continuing entitlement to this payment, as per paragraph 14, infra, of this Agreement.
d. Lumo sum pavment: Husband agrees to pay Wife, in one undivided payment,
the sum ofSI8,500.00. This payment shall be made at the execution of this Agreement.
7. SPOUSAL SUPPORT/A PL/A LlMONY: Husband is currently paying Wife spousal
support/apl in the amount ofS350.00 per month. The parties agree that this obligation shall terminate
effective the date the divorce decree herein issues, but only if there are no arrears on the account, in
which case the obligation shall not terminate until all such arrears have been paid in full and
distributed to Wife.
Wife agrees to provide the Cumberland County Domestic Relations Office with a copy of this
Agreement and of the divorce decree and to request termination of the Support Order in accordance
with this paragraph within five (5) days of her receipt of the decree.
8. TAXES: Husband and Wife warrant that neither owes any taxes, interest or penalties
for which the other might be liable and they agree that should any sums be currently or become due
as a result of their individually or jointly filed returns, for either the tax year 2000 or any previous year
of their marriage, the party which filed the return on which the taxes, interest or penalties are due or
who was responsible for the deficiency or penalty on any joint tax return shall be solely responsible
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for all sums due, He/she agrees to indemnify and hold harmless the other party on all such
obligations.
9, COUNSEL FEES, COSTS AND EXPENSES: Each party is represented by counsel
of his or her choice and each agrees to pay his or her own legal fees, costs and expenses, without
claim against the other,
10. BANKRUPTCY OR REORGANIZATION PROCEEDINGS: The parties agree
that none of the obligations created by this Agreement, whether in Husband or in Wife, shall be
discharged or dischargeable in any bankruptcy or financial reorganization proceeding initiated by
either, regardless offederal or state law to the contrary.
I\. WAIVER OF RIGHTS: The parties waive all other past, present and future rights
provided in the 1980 Divorce Code, as amended, or any future laws and amendments including their
right to alimony, spousal support, equitable distribution, alimony pendente lite, costs and expenses,
and attorney's fees, except as otherwise provided herein.
12. SUCCESSORS' RIGHT AND LIABILITIES: This Agreement shall, except as
otherwise provided herein, be binding upon and inure to the benefit of the parties hereto, their
respective heirs, executors, administrators, successors, and assigns.
8
13, ENTIRE AGREEMENT: Wife and Husband do hereby covenant and warrant that
this Agreement contains all of the representations, promises and agreements made by either of them
to the other for the purposes set forth in the preamble hereinabove; that there are no claims, promises,
or representations not herein contained, either oral or written, which shall or may be charged or
enforced or enforceable unless reduced to writing and signed by both of the parties hereto; and the
waiver of any tenn, condition, clause or provision of this Agreement shall in no way be deemed to
be considered a waiver of any other terms, conditions, clauses or provisions of this Agreement.
14. A DDlTlON A L I NSTR U M ENTS: The Husband and Wif-: shall, at any and all times,
upon request by the other party or his or her legal representatives, make, execute, and deliver any and
all such other and further instruments, deeds, notes, releases, car titles, tax forms, insurance fonns,
or such other writings as may be necessary or desirable for the purpose of giving full force and effect
to the provisions of this Agreement and as their respective counsel shall mutually agree should be
executed in order to fulfill promptly the terms of this Agreement.
15. GOVERNING LAW: All matters affecting the interpretations of this Agreement and
the rights of the parties hereto shall be governed by the laws of the Commonwealth of Pennsylvania.
16. INDEMNIFICATION UPON BREACH: (ffor any reason either the Husband or
the Wife fails to perfornl his or her obligations hereunder to the other spouse, and the other spouse
incurs any expense thereby (including but not limited to legal fees) in enforcing his or her rights, the
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spouse who failed to perform the obligations agrees to reimburse and indemnify the other spouse and
hold him or her harmless for any and all such expenses.
Each party hereby agrees to pay all attorney's fees and costs oflitigation that the other spouse
may sustain or incur in any way whatsoever as a consequence of any default or breach by the other
spouse of any of the terms or provisions of this Agreement; provided that the party who seeks to
recover such attorney's fees and costs oflitigation must first be successful in whole or in part, before
such liability may be imposed. It is the specific agreement and intent of the parties that a breaching
or wrongdoing party shall bear the burden and obligation of any and all costs and expenses and
counsel fees incurred by himself or herself as well as the other party in endeavoring to protect and
enforce his or her rights under this Agreement.
17. INDEPENDENT COVENANTS: Each of the respective rights and obligations of
the parties hereunder shall be deemed independent and may be enforced independently irrespective
of any of the other rights, and obligations set forth herein.
In case any provision of this Agreement should be held to be contrary to, or to be invalid
under, the law of any country, state or other jurisdiction that is applicable to this Agreement, such
illegality or invalidity shall not aficct in any way other provisions hereto, all of which shall continue,
nevertheless, in full force and elTect under the law of the country, state or other jurisdiction that is
applicable to this Agreement.
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18, NO MERGER IN DIVORCE DECREE: In theevenllhat eitherofthe parties shall
recover a final judgment or decree of absolute divorce against the other in a court of competent
jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but
shall not be deemed merged into such judgment or decree of absolute divorce and shall be entirely
independent thereof.
19. SUBSEOUENT DIVORCE: There is pending between the parties an action for
divorce instituted by Husband in the Court of Common Pleas of Cumberland County, Pennsylvania.
Husband and Wife agree that their marriage is irretrievably broken and that the same shall be
dissolved pursuant to Section 3301(c) of the Divorce Code of Pennsylvania (mutual consent). The
parties, therefore, agree as follows:
a. That upon the execution of this Agreement, they will both sign an
Affidavit of Consent and Waiver of Notice pursuant to Section
3301(c) of the Divorce Code;
b. That Husband shall be responsible for completing the divorce, by filing
the Praecipe To Transmit with this Agreement attached, and that he
will do so within ten (10) days of the execution of this Agreement and
the Affidavits of Consent; and
c. That neither has requested marriage counseling and each hereby
waives his/her right to demand same.
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~:\OFFICE\WPWIN\WPDOCSIOOMESTIC\CCMPLAIN\KEISTER .WPO
June 30,1997
REAGER & ADLER, PC
BY: DEBRA DENISON CANTOR, ESQUIRE
Attorney 1.0. No. 66378
2331 Market Street
Camp Hill, PA 17011
Telephone: (717) 763-1383
Attorneys for Plaintiff
RICHARD E. KEISTER,
Plaintiff
: IN TilE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
NO. q7 - 35"85 CW.J.. Ti-
v.
BEVERLY ANN KEISTER,
CIVIL ACTION - LAW
DIVORCE
Delcndant
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT If you wish to defend a~ainst the claims set forth in the
following pages, you must take prompt action. You are warned that ir 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 III 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 sround 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, Room 101, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROI'ERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEI\I.
YOU SIIOULD TAKE TillS I'APER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT IIA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE TilE OFFICE SET FORTII BELOW TO FIND OUT WHERE
YOU CAN GET LEGAL IIELI'.
Cumberland County l.awyer Relcrral Service
Court Administrator
South Hanover Street
Carlisle, PA 170.J.1
(717) 2.JO-6200
C:\OFFIC:E\WPWIN\WPDOCS\DOMESTIC\COMPLAIN\KEISTER .WPD
. June 30. 1997
12. Plaintiff and Defendant have acquired property, both real and personal, during their
marriage.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to equitably divide all
marital property and debt.
Respectfully Submitted,
REAGER & ADLER, PC
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Date: June 30, 1997
By:
Attorneys for Plaintiff
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RICIIARD E. KEISTER,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY. PENNSYLVANIA
v.
NO, 97-3585 Civil Tenn
BEVERLY ANN KEISTER,
Dclcndant
CIVIL ACTION - LAW
IN DIVORCE
A"FIDA VIT OF CONSENT
I. A l'llIl1plaillt ill divorcc under scction 3301(c) of the Divorce Code was filed on July I,
1997.
2. Thc marriagc of Pia inti ffand Def~ndant is irretrievably broken and ninety (90) days have
e1apscd 1r.1I11 thc datc of tiling ami scrvice of the Complaint.
J. I conscnt tothc cntry ofa final dccree of divorce aner service of no lice of intention to
rcqucst cntry of thc dccrcc.
-I. lundcrstand lhatlmay lose rights concerning alimony, division of property, lawyer's fees
or cxpcnscs if I do 1I0t claim thcm before a divorce is granted,
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I vcri fy thai thc statcmcnts made in this affidavit arc true and correct. I understand that false
statcmcnls hcrcin arc madc subjcct to Ihepenalties of 18 Pa.C,S, ~ 4904 relating to unsworn falsification
to authoritics.
Ililtcd ) I :) I I (I i
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RICHARD E, KEISTER
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Date: :9. /71 (: n
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KEISTER (DEFENDANT)
RICIIAltD E. KEISTER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
BEVERL Y ANN KEISTER,
DEFENDANT
NO, 97-3585 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AFFIDA VIT OF CONSENT
I. A complaint in divorce under ~3301(c) of the Divorce Code was filed on July I, 1997,
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date offiling and service of the Complaint.
3. I eonsentto the entry of a final decree in 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 made herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn
falsification to authorities.
RICHARD E. KEISTER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
BEVERLY ANN KEISTER,
DEFENDANT
NO. 97-3585 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE
DECREE UNDER S3301(c) OF TilE DIVORCE CODE
I. I consent to the entry of a linal 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. 94904 relating to unsworn
falsification to authorities.
Date , ,J / -:"'f!{c '
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BEVERLY/ NN KEISTE (DEFENDANT)
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Julya. 1997
4
REAGER & AJ)LER, I'C
BY: DElmA J)ENISON CANTOI{. ESQlIIRE
Attorney I.D. No, 66378
2331 Market Street
Camp Hill, I'A 17011
Telephonc (717) 763-1383
Attorncys for l'laintitr
RICHARD E KEISTER,
Plaint ill'
IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
Detcndant
NO 97-3585 CIVIL TERM
CIVIL ACTION - LAW
ACTION IN DIVORCE
v
BEVERL Y ANN KEISTER,
A 1'1' I() A VIT OF SEIH'ICE
I, Debra Dcnison Cantor, Esquirc. bcing duly sworn according to law, dcpose and statc that
service of the Complaint in Divorcc in thc ahovc-captioncd mailer was servcd by ceniticd mail,
restricted delivcry, on the Delcndant, Bc\'crly Ann Kcistcr at Kcnneth & Co , 3030 1\1arket Strcet, Camp
Hill,I'A 17011 on July 5. 1997 Thc certilied receipt is allached herelo as "Exhibit A"
Rcspecttilll~' Suhmilled,
Date July S, 1997
B~'
"
2.1.11 Market St recI
Camp lIill. 1'/\ 17011-4642
Telcphonc No 1717J 763-138.1
Allorncvs li,r I'laintilr
July 6. 1997
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. AlIICIIlIlIIform 101110 llor1Iolll1o maIlpIoco, DlDlIII10 bad<Kopaco
doeInoIpermI.
- 'TlllRolornRocolptwlllohawlllwhomll1oll1lclo__ondll1ollm ..
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3. ArtIcle Ad to:
Mrs. Beverly Ann Keister,.__
c/o Kenneth & Co.
3030 Market street
Camp Hill, PA l70l1
I iIeo wIIh to.... the i
l81V1cea(foren_lIle): I
1. Addreaaee'IAddresa I
ft~esuIclBdDeUwlry~ , !
Coe~rforfee.
4a. Artlcle Number
DlIS
4b.SoMce~ 00 CERnAED
7. Dale of Delivery - - -'I
8. Addressee'. Add",.. (Only W mquooted
end foe 10 paid)
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@MAY 2 0 1998
RICHARD E, KEISTER.
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY. PENNSYLVANIA
Plaintiff
v,
NO. 97-3585 CIVIL TERM
CIVIL ACTION - LA W
DIVORCE
BEVERL Y ANN KEISTER.
Defendant
ORDER OF COURT
AND RULE TO SHOW CAI.JSE
AND NOW. this 22....... day of
~
,
. 1998, a Rule is entered upon Defendant.
Beverly Ann Keister. to show cause why the rcliefrequested in Plaintiffs Petition should not be granted.
This Rule is returnable fifteen (15) days after service. If an answer if liIed by Defendant, the
Prothonotary shall forward the answer to the Judge's Chambers,
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WHEREFORE. Plaintiff requests this Honorable Court to issue an Order granting Plaintiff special
relief and the return of his premarital property,
Respectfully Submilled,
REAGER & ADLlm,l'C
Date: May 15. 1998
By:
2331 Market Street
Camp Hill. PA 17011-4642
Telephone No, [7171 763-13R3
Attorneys for Plaintiff
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ATTORNEYS AT LAW
2331 MARKET STREET
CAMP HILL. PA 17011-4S42
(717)763.1383
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EXHIBIT A
WllERErORE, Plaintiff rcqucsts this Ilonomhlc Court to issuc an Ordcr gr:1Il1ing Plaintiff spccial
relicf and the retuJ'll of his prem:lrital propCrly,
Rc.,pcctfully Suhmillcd,
REAGER & ADUm, PC
D:lle: May 15, 199M
By:
2331 Markcl Slrccl
Camp Hill,l'A 17llll-4M2
Tclcphonc No, 171717(,3-I3H3
AllOnlCYS for PlaintilT
2
EXHIBIT B
J.
RICHARD E, KEISTER,
: IN THE COURT OF COMMON PLEAS
:CUMDERLAND COUNTY,PENNSYLVANIA
Plninliff
v,
NO, 97.3585
BEVERLY ANN KEISTER,
CIVIL ACfION . LA W
Defendnnt
DIVORCE
ORDER
AND NOW, this 3D dnyof ~-
, 1998, upon considerntion of
Plnintifrs Petition for Specinl Relief nnd Motion to Make Rule Absolute, the Plaintifrs request
for specinl relief is hereby GRANTED,
Defendnnt is directed to return the property identified in Plaintifrs Exhibit "A" to his
Petition for Specinl Relief within thirty (30) days of the date of service of this Order,
IS / &/~<t-u ,,:;, J5.('o'...1-/?,1
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EXHIBIT C
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HISTocoum
Exhibit D
No. 6303
FAX TRANSMISSION
REAGEIl ,,\: Allum, PC
2.33 I f'.'ARKC.T STRceT
CAMP HIL.L. PA 1 70 I I
717'703.1303
FAX 7 I 7.730'7300
To:
Mark Durrie
Dalc:
Ocloller S, IlJlJS
Fax#:
Pagcs:
onc, including Ihis cover sheet.
From:
Subjccl: Keisler
COMMENTS:
This confirms Ihat Dick will obtain the ilems outlined in Ihe courl Ordcr IOlllorrow Illorning at
10:30 a.m. at the West Shore Plaza in the D.lUphin Deposil parking lot. If this is not acceptuhle,
please contacl me as soon as possible.
Please indicale an acceptable lime and dale for your client to pick up Ihe fish and Diek will mect
her in Maryland 10 pick il up.
Finally, Dickjust received notice from Ihe IRS that Ihcre was connicl in Ihe incollle tax filing for
1996. Apparently, your client filed man'ied filing sepamle. This filing will cost Dick an
extraordinary amount of money. We are requesting lhal the parlies file an amended joint retUIl1.
Any refund will be divided. Any obligation will be paid by Dick. Please review Ihis issue wilh
your client and get back to me.
Your cooperation is appreciated.
RICHARD E. KEISTER,
PLAINTIFF/PETITIONER
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
BEVERLY ANN KEISTER,
DEFENDANnRESPONDENT
,
V.
97-3585 CIVIL TERM
ORDER OF COURT
AND NOW, this 20th day of November, 1998, Beverly Ann Keister is ordered to
pay $150 toward Richard E. Keister's counsel fees for enforcement of a court order
not later than thirty (30) days from this date.
!iiw.
Edgar B. Bayl y J.
Debra Denison Cantor, Esquire
For Richard E. Keister ",,';".{,.{ / II :J.( /93
c.~<v ....5 f'
Mark Duffie, Esquire
For Beverly Ann Keister
:saa
LAW OFFICES
JOHNSON, DUFFIE. STEWART (I WEIDNER
DEC21~
Telephone (717) '61-1540'
Telecoplcr (717) 76103015
IN THE COURT OF COMMON PLEAS OF . ""-'
CUMBERLAND COUNTY, PENNSYLVANIA
..' 301 ~r1cct Street
P. O. Box 109
Lemoyn., Penn.ylv.nl. 17043.0109
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RICHARD E. KEISTER,
Plaintiff
v.
NO. 97-3585 - CIVIL TERM
CIVIL ACTION - LAW
DIVORCE
BEVERLY A. KEISTER,
Defendant
ORDER OF COURT
~ ., i
AND NOW. this)1 day of
A(c(,,\,(~
. 1998, upon consideration of the attached
Petilion for Special Relief, it is ordered and decreed that a hearing on the issues contained therein is schedule
')
. 199~. in Court Room
for the I 'i LV. day of _" j " " " \ '\
I ()
Court of Common Pleas. Ond Courthouse Square. Carlisle, Pennsylvania. {( (
.:? of the Cumberland County
{:(le.' !' III.
BYTHE COU~T/ J j
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010833.00001l12.17.981MCDiPARl117098.1
7. The odometer reading on the Fleetwood Ford Bounder at the time of purchase was 22,582
miles.
8. Plaintiff has driven the 1991 Fleetwood Ford Bounder to Alaska from his him home in Worton,
Maryland, without the Defendant.
9. Plaintiff is repealedly driving the 1991 Fleetwood Ford Bounder to Canada and other places
throughout the United States.
10. Plaintiff is devaluing the 1991 Fleetwood Ford Bounder vacationing with it all over North
America.
WHEREFORE, Defendant requests this Honorable Court to issue and Order granting the Defendant
special relief, directing Ihe return of her premarital property and directing Plaintiff to refrain from further use of
the 1991 Fleetwood Ford Bounder motor home.
Respectfully submitted,
JOHNSON, DUFFIE, STEWART & WEIDNER
By:
DATED:
.1998
010B33.00001l12.17.9B1MCDIPAR/11709B.1
. .
EXHIBIT "A"
Defendant, Beverly A. Keister's premarital property:
1. Grill
2. Sailfish
3. Stereo Dry Sink
4. Refrigerator and Freezer (side by side)
5. End Unils to Entertainment Center
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JOHNSON, DUFFIE, STEWART & WEIDNER
FEB 0 ~ 1999
301 M"k.. 5.",..
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Lemayn., Penmylvonl. 17043.0109
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Telephone (717) 761-1540 ..
Telecopler (717) 76\.3015
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RICHARD E. KEISTER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-3585 - CIVIL TERM
CIVIL ACTION - LAW
DIVORCE
Plaintiff
v.
BEVERLY A. KEISTER,
Defendant
ORQER OF COUBI
"I i} 9
AND NOW, this ,. day of . (L'\.tl<t cJ . 199~, upon consideration of the attached
Amended Petition for Special Relief, it is ordered and decreed that a hearing on the issues contained therein is
scheduled for the 4th day of March. 1999, at /. 'I) i:L.M, in Court Room 1..
of the Cumberland
County Court of Common Pleas, One Courthouse Square. Carlisle, Pennsylvania.
~
/
J.
010833.00001l1.14.99/MCDIPAR/118917.1
RICHARD E. KEISTER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
97-3585 CIVIL
BEVERLY A. KEISTER,
Defendant
CIVIL ACTION - LAW
DIVORCE
AND NOW COMES Defendant, Beverly A. Keister, by and through her attorneys, Johnson, Duffie,
Stewart & Weidner, and in support of this Petition avers as follows:
1. Plaintiff and Defendant were married on February 26, 1988.
2. The parties resided together until January, 1997.
3. A Complaint in Divorce was filed on July 1,1997.
4. Plaintiff is in possession of several items of premarital property belonging to Defendant, which
are itemized in Exhibit "A", which is attached hereto and incorporated herein.
5. Plaintiff has refused to surrender any of the premarital property attached as Exhibit "A".
6. On December 1,1995, Plaintiff and Defendant purchased a 1991 Fleetwood Ford Bounder, VIN
3FCMF5382LJA02597.
7. The odometer reading on the Fleetwood Ford Bounder at the time of purchase was 22,582
miles.
8. Plaintiff has driven the 1991 Fleetwood Ford Bounder to Alaska from his him home in Worton,
Maryland, without the Defendant.
RICHARD E. KEISTER,
: IN TI-IE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
NO. 97-3585 Civil Tcrm
BEVERLY ANN KEISTER,
CIVIL ACTION - LAW
Dcfendant
IN DIVORCE
OIUlER
AND NOW, this 2- 5 day of {0MJcu.-..
, 1991J, lhe Spceial Relief Hcating
\
in this malleI' is continucd generally pending rcschcduling by the panics.
,
BY THE COURT:
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Edgar B. Bayley, Judge
REAGER & ADLER, PC
A llORNLYS AND (OI)NSUORS AT LAW
JIll M^R~IT ~HUlT
eMU' lUll. I'{NN\HVANIA 171111,"1.41
717.71>1-11111
lltlr^' i'17.71U.1Ihh
\\'[IISIl{: Ilt',l~t'l^drl',I'C.(orTl
IHEOOORE A. ^mn~'+
DAVID IV. RfAGfR
LINUS L fENICU'
DEIlRA DlNISON CANTOR
THOMAS O. WilliAMS
SUSAN H. CON fAIR
JULIE A. McCONAHY
Fehruary II). 11)99
It>g.11 Aui\'olnl\:
IENNlfER S. KUHNS
SUSANNE K. SATHER
MONICA D. ZERCHER
"AI!.(} oldmilll"d to D.C. B.H
'Also admilll>d 10 Ohio D.H
Honorable Judge Edgar B. Bayley
Cumberland County Counhouse
One Counhouse Square
Carlisle, PA 17103
RE: Kcislcr v. Kcistcr
No,: 97.3585 CIVIL TERM
Our Filc NO.: 97.32-1
Dear Judge Bayley,
The panies in this malleI' are allempling to come to a final resolution of their equitable
distribution isslles. Counsel for Mrs. Keister is in the process of drafting the proposed
agreement. Therefore, counsel is requesting a general continmll1ce of the Special Relief Petilion
hearing scheduled for March 4,1999, pending a finall'esolution. (I' we arc unable to come 10 a
prompt resolution. we will contact your chambers to reschedule Ihe hearing.
Your allention and cooperation is gre.llly appreciated. I bave allaehed a proposed order
for your convenience.
Very truly 'ours.
/)lvIJ2l (LeL
~bra Denison ,111101'
DDC/cms
Enclosure
cc: Mark Duffic. Esq.
Dick Keister
+ (("Jllil'd .l~ .1 (',\11 111.11 ~Pl'( 1.\Ii" h\ tht. N,IIIClfl.llllu,lId III TrI,11 !\d\llt ,j( )'. A I't'llll,)h,lIH,J SUPU'l11t' ('ollrl Ace It'dllt'd A~t,l\t),
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-3585 CIVIL TERM
RICHARD E. KEISTER,
PLAINTIFF
BEVERLY A. KEISTER,
DEFENDANT
DIVORCE
PRAECIPE
Please withdraw my appearance on behalf of Beverly A.
Keister, Plaintiff above-named.
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MarC. Duffie \
Johnson, Duffie, stewart & Weidner
301 Market Street
Lemoyne, PA 17043-0109
(717) 761-4540
Please enter my appearance on behalf of Beverly A. Keister,
Plaintiff above-named,
Date
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Marilyn C. Zil~ESq.
Fetterhoff and Zilli
200 N. Third street, suite
Harrisburg. PA 17101
(717) 232-7722
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RICHARD E. KEISTER,
Plaintiff/Respondent
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-3585 CIVIL TERM
BEVERLY ANN KEISTER,
Defendant/Petitioner
CIVIL ACTION - LAW
IN DIVORCE
ORDER
AND NOW, this l6 day of JlMR- ' 1999 an injunction
is issued against Richard E. Keister. Plaintiff/Respondent,
prohibiting his dissipation/alienation or other disposition of
all marital assets in this case. In addition, it is specifically
ordered that if the property which Plaintiff/Respondent owns i~
Kent County, Maryland is sold he shall immediately escrow in an
interest-earning account in the names of Petitioner and
Respondent all proceeds from the sale of that property without
dissipation of any of the monies received and shall provide a
complete accounting of settlement on the property and deposit of
the monies to the Court.
A hearing on Petitioner's Petition for Special Relief [23
Pa.C.S.A. ~3323(f)] and/or for Injunction [23 Pa.C.S.A. ~3505(a)]
is scheduled for ~ ~ X J ~ at ~ (")0 WI_
in Courtroom No. _-II:: ~ c.Aa,.~""",~ .J.1 fvU
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19. This promise also induced Petitioner to co-sign the
mortgage(s) with Respondent and to incur additional indebtedness
when it became clear that the first mortgage(s) would not be
paid.
20. Respondent did not sell the Maryland property and also
refused to work. Petitioner's salary as an office worker was not
suff icient to pay all of the parties' monthly debt. As a
consequence, the parties' defaulted on the Halifax Bank loans. An
additional loan was secured in order to make payment on the
original loans current.
21. Because of Respondent's broken promises. the parties
were forced to sell the Lewisberry property. However, the
proceeds from this sale were not sufficient to satisfy the
outstanding mortgages and foreclosure was threatened.
22. Foreclosure would have resulted in Respondent's loss of
the Maryland property through sheriff's sale.
23. In order to prevent the loss of this property,
Petitioner agreed to accelerate the terms of a sales agreement
she had on a piece of real estate which she owned prior to the
marriage, and to take a loss on that agreement in order to
provide an additional $46,000.00 to satisfy the Halifax Bank
loans.
24. In exchange for her preservation of the Maryland
property, Respondent agreed to deed the property in both parties'
names and that the parties would live in that residence.
25. Respondent never transferred the property into joint
names. He continues to hold the Maryland property in his own
name.
26. Petitioner asserts an interest in the Maryland property
either because of an increase in the value of the property during
the marriage, or because the property became marital when pledged
as collateral for the Halifax Bank loans, or because of
Respondent's promises to her or because of Respondent I s
intentional fraud on her and the bank or because the $46,000.00
she provided to save the property for Respondent was a loan only
which Respondent must now repay.
27. If the Maryland property is sold. Respondent will be
able to retain and/or dissipate the entirety of the equity in the
property and the proceeds of the sale without making any
provision to satisfy petitioner's interest therein.
I
28. Petitioner requests that an Order issue directing that,
if the Maryland property is sold, Respondent escrow in an
interest-earning account in the names of Petitioner and
Respondent all of the proceeds from the sale, without dissipation
of any of the monies received, that he provide a detailed
accounting to the Court of all monies disbursed and received at
settlement and of the deposit of the proceeds into the escrow
account, including the name and address of the bank where the
funds were deposited and the number of and names on the escrow
account.
29. Respondent is also in possession of other marital
assets, including a mobile home and a number of boats or other
boating equipment.
30. Petitioner believes that Respondent is using these
items for his own pleasure, without consideration of her interest
therein, and that he will then claim that the items have
decreased in value because of this use, or because of damage
which he has himself caused.
31. Petitioner requests an Order prohibiting Respondent
from further dissipation of all other marital assets.
:'l~:R:r;F_I~~';I.'lQli
I verify that the statements made in the foregoing docllm"nt
are true and correct to the best of my knowledge, lInderstandinq,
and belief.
I understand that false statements herein are m~n"
subject to the penalties of 18 Pa. C.S. ~4904 relating to lInnwnrn
falsification to authorities.
Dilte: (p - /(, - tt1
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5. Neither party will sell, transfer, dissipate, encumber
or otherwise alienate any property in their sole possession ',r
control which is marital or whose value or any part thereof is
marital without the express written consent of the other.
6. In the event any marital asset or property whose value
or any part thereof is marital is sold, the proceeds from said
sale shall be deposited into a newly established jointly held
("and") escrow account in the names of both parties pending final
resolution of all equitable distribution claims.
7. If as of July 7, 1999, any marital asset or property
whose value or any part thereof is marital has already been sold
the party who sold the asset shall make a complete written
accounting of the sale for the other party, by a date no later
than July 15, 1999, and shall thereafter escrow whatever sum was
received on the sale in the aforesaid escrow account.
8. Except for the furniture already in their possession,
neither party shall use any item of marital property until final
resolution of all equitable distribution claims, As an exception
to this provision, however, it is noted that Plaintiff Husband is
currently occupying the parties' jointly owned Bounder motor
home.
Plaintiff Husband shall be permitted to continue to
occupy this property until equitable distribution has been
determined.
9. If the Worton, Maryland property is sold, Plaintiff
Husband will escrow in the aforesaid jointly held escrow account
all of the proceeds from the sale, without dissipation of any of
the monies received. He will provide a detailed accounting to
Defendant Wife of all monies received and disbursed at settlement
and of the deposit of the proceeds into the escrow account.
"
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By (" C07/~
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Edgar B. Bayley, Judge
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5. The parties hereby agree that neither will sell,
transfer, dissipate, encumber or otherwise alienate any property
in their sole possession or control which is marital or whose
value or any part thereof is marital without the express written
consent of the other.
6. The parties hereby agree that in the event any marital
asset or property whose value or any part thereof is marital is
sold, the proceeds from said sale shall be deposited into a newly
established jointly held ("and") escrow account in the names of
both parties pending final resolution of all equitable
distribution claims.
7. The parties hereby agree that if as of July 7, 1999,
any marital asset or property whose value or any part thereof is
marital has already been sold the party who sold the asset shall
make a complete written accounting of the sale for the other
party, by a date no later than July 15, 1999, and shall
thereafter escrow whatever sum was received on the sale in the
aforesaid escrow account.
8. The parties hereby agree that except for the furniture
already in their possession, neither shall use any item of
marital property until final resolution of all equitable
distribution claims. As an exception to this provision, however
it is understood and acknowledged that Plaintiff Husband is
currently occupying the parties' jointly owned Bounder motor home
and that he will continue to do so.
9. The parties specifically agree that if the Worton,
Maryland property is sold, Plaintiff Husband will escrow in the
aforesaid jointly held escrow account all of the proceeds from
the sale, without dissipation of any of the monies received and
that he will provide a detailed accounting to Defendant Wife of
all monies received and disbursed at settlement and of the
deposit of the proceeds into the escrow account.
WHEREFORE, the legal representatives of both parties, being
duly authorized as agents thereof, hereby place their signatures
below signifying the full and binding agreement of their clients
to the terms of the herein stipulation.
Date:
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FETIERHOFF AND ZILU
ATTORNEYS AT LAW
200 N. THIRD STREET. SUITE 8~0
P.O. BOX 1161
HARRISBURG. PENNSYLVANIA 17108
WILLIAM /11.. FETTERHOFF
MAAILYN C, tiLL!
TELEPHONE
717.232.7722
'AX
717.233.<4g55
July 12, 1999
The Honorable Edgar B. Bayley
Cumberland County Court of Common
Cumberland County Courthouse
1 Courthouse square
Carlisle, PA 17013
Pleas
Re:
Keister v. Keister
No. 97-3585 civil Term
In Divorce
Dear Judge Bayley:
I enclose a stipulation signed by counsel for both parties
in the above-noted case by which Wife's Petition for Special
Relief was resolved. You will remember that a hearing on this
Petition had been scheduled for July 7, 1999. I also enclose an
Order based on the stipulation.
I would appreciate it if you would sign the Order and the
copies enclosed. The original of the Order can then be filed.
Please return the copies to me in the self-addressed stamped
envelope I have enclosed. I will make distribution to Ms.
Cantor, Husband's attorney.
Thank you for your attention and cooperation.
w:~(:}{~
Enclosures
cc: Ms. Beverly Keister
Debra Denison Cantor. Esquire
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RICIIARD E. KEISTER,
PlainlirrJRcspondcnl
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION. DlVOItCE
BEVERLY ANN KEISTER,
Dcfcndanl/Pclilioncr
NO. 97 - J~8~ CIVIL TERM
IN DIVORCE
DRII 28771
Pac~c~# 1ll1l1112~6
ORDER OF COURT
AND NOW.lhis I 9'" day of Jnly. 1999. npon considcralion oflhc allachcd Pclition for Alimony
Pcndcnlc Lilc and/or connscl fccs. it is hercby dircclcd thallhc pallies and Ihcir rcspecli\'c counscl appear
beforc R.J. Shadda\' on A/ll!u.\1/0. /999/119:110 A.M. for a confcrcncc. aI D N. Hano\'cr SI.. Carlislc. PA
1711 D. ancr which Ihc confcrcncc officcr may recommcnd Ihal an Ordcr foc Alimony Pcndcntc Lilc be
clllcrcd.
YOU arc fUllhcr ordcrcd 10 bring 10 Ihc confcrcncc:
(I) a Imc copy of your mosl rCCclll Fcdcrallncomc Tax RClnlll. including \V-2's as filcd
(2) your pay slnbs for Ihc prcccding si.x (6) monlhs
(J) thc Incomc ,md Expcnsc Slalcmcnl allachcd 10 this ordcr, complClcd as rcquircd by Rulc
19111.III~
(4) \'crific'lIion of child carc cxpenscs
(5) proof of mcdical CO\'ccagc which yon may ha\'e. or may ha\'c a\'ailablc 10 yon
IF you fail 10 appear for Ihc confcrcncc or bring Ihc rcqnircd documcllls. lhc Conllmay issnc a
warrant for )'our arrest.
..
BY THE COURT.
Gcorgc E. HolTcr. Prcsidclll Jndgc
mailcd copics 10: Pclilioncr
7-19-99 Rcspondclll
Dcbra Dcnison Canlor. Esq.
Marilyn Zilli. Esqnirc
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Dalc ofOrdcr: Jull' 19. 1999
,R: 1. Sh~dda\'. tonfcrcnce Officcr
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YOU IIAVE TilE RIGIIT TO A LAWYER, WIIO MAY ATTEND TilE CONFERENCE AND
REPRESENT YOll. IF YOll DO NOT IIAVE A 1.AWYER OR CANNOT AFFORD ONE, GO TO
OR TELEPIIONE TilE OFFICE SET FORTII BELOW TO FIND OllT WIIERE YOll MA Y GET
1.EGA1. IIELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE. PENNSYLVANIA I7I1Il
(717) H'J-11(,(.
b. Defcndmll:
I. Name: Beverly Ann Keisler
2. CUITCnl Addrcss: 1021 Kenl Drive,
Mechaniesburg, Pa, 17055.
3. Date of Binh: Dccember 21), 1944
4. Social Security Numbcr: 217 -46-6980
WHEREFORE, Plainli 1'1' moves this COlllt to schcdule a conference in front of 1I
Domcstic Relations Officer.
Respeclfully Submitted,
ImAGER & ADLEIt, PC
Datc: July 13, 1999
(.
By: '1 r>-t L I
DEBR,A DENISO ANTOR, ESQUIRE
AttQm/:y J.D. ~o. ~ 378
-~
233! Market Street
Camp Hill, PA 17011-4642
Tclephone No. 1717] 763-1383
AttoIl1eys for Plainliff/Petitioner
Exhibit A
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In the Court of Common Plell~ of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
RICHARD E. KEISTER, ) Docket N umher 97-3585 CIVIL
Plaillliff /Respundcnt )
VS. ) PACSES Case Number 101101256/D28,771
BEVERI.Y ANN Kf:ISTER, )
Defendant/Pet I.t luner ) Other Slale ID Numher
Qillr
AND NOW 10 Wi1, this
AUGUST la, 1999
it is hercby Ordcrcd
1hat:
THE ABOVE PETITION FOR ALIMONY PENDENTE LITE IS DISMISSED, WITHOUT PREJUDICE,
PURSUANT TO AN ORDER OF SPOUSAL SUPPORT BEING ESTABLISHED ON THIS DATE.
4
BY THE COURT:
DRO: RJ Slndday
malled xc: petltluner
8-t7-99 I respundent
D. C.llltur, Esq.
'I. Z I 111. Esq.
~.1:f /} J.
Kevin A,' ess
JUDGE
,
FomIOE.()()!
Wnrker 10 21005
Service TyJlC M
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REAGER & ADLER, PC
ATTORNEYS AND COUNSElORS AT LAW
.!Ill MAI{I\II !tTHIET
(A.'"'lml, 1'("'N"'~I\'M..jII' !:oml..u......
71i.ih 1.llft I
1(1(f^X 71 7.7 11J.i'lhh
W(Il~ll[: Rt..I~I'r^drl',I'c.(llll\
THW[>ORE A. ADLER"
DAVID W. REAGER
LINUS E. fENICU'
DEBRA DENISON CANTOR
THOMAS O. WilliAMS
SUSAN H. CONrAIR
IULlE A. M, CONAHY
November 23. 11)1)8
Ll'K.11 ^\\i\l.ml\:
JENNIfER S. KUHNS
SUSANNE K. SAUtER
MONICA D. ZIRCHER
-AI\(1 ,l<lmilh.d to D.C. Bolf
.^I~n .ulmiltl'tlln Ohin (1M
Honorable Judge Edgar B. Bayley
Cumberland County Courthouse
One Courthouse Square
Carli .~
RE: Kcistcr \'. Kcistcr
No.: 1)7-3585
Our Filc No.: 97-324
\Y
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< It VJ~ U
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Dear Judge Bayley:
Enclosed please findlhe invoices for the above c,IPtioned mailer. I have included all
invoices related to illY allempts for enforcement of the JLlne 30. 11)98 Order, as well as the
Petilion for Contempt and our conference call. I have also cnclosed a drafl Order for your
review. By copy of this correspondence. [ have provided AlloIl1ey Duffie with Ihe invoices as
well.
Your allention is greatly appreeialed.
Very Intly yours.
/i3~,
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,
DDC/cms
Enclosures
ec: Richard Keister
Mark Duffie, Esq.
+ (t'rtllll'd .1" .l (',...11 T".11 Spt., 1.11i,1 hy tht, N,IIIlII1.11 BII,utl oj 111,11 Ad\t)!.j{ y. i\ I't'nrh~h,lJll.l I.,UPIl'lllt' (-.HIII ,\(( !I'dlh'tl f'!~I'I\()'
11-03-98
Richard E Keister
25113 Wymont Park Road
Worton MD 21678
4007 -
Divorce
0936
Date Action
Time
Amount
10/05/98 Telephone Call with client regardin status of pick
up, IRS, telephone call to Attorney Duffie
10/08/98 Telephone Call with Attorney Duffie's office
regarding status
10/08/98 Telephone Call with Attorney Duffie, letter to
Attorney Duffie, telephone call with client
10/09/98 Telephone Call with client, with attorney Duffie
three times
10/13/98 Draft Pleadings Contempt petition and order,
review file
0.20
20.00
0.20
20.00
0.30
30.00
0.40
40.00
1. 00
100.00
Debra Denison Cantor... 2.10
210.00
10/30/98 Copies
10/30/98 Postage
9.00
3.44
Total Time:
2.10 hrs.
Prior Balance Due: $
Services this period: $
Disbursements: $
462.65
210.00
12.44
Current Trust Balance: $
0.00
AMOUNT NOW DUE:
$
685.09
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REAGER & ADLER, PC
^,lOlltl[Vf, AW) COUt15nons AT LAW
;'3:11 MMIK[T STnEET
CAMf' Hill. I'^ 1101t.4642
117.7/iJ.I:]8J
10-12-98
R1ehnrd E Keister
25113 Wymont Purk Rond
Worton MD 21678
4007 -
IJ i \'orce
0936
Date
Action
Time
09/10/98 Te I ephone CU II wi t h Mnrk Duffie 0.20
09/16/9S Te I cphone Cn I I wi t h Duffies office and with client
re: item pick-up 0.40
09/25/98 Te I ephonc eu II wi th Mark Du ff i e 0.20
09/28/98 fe J ephone Call wi t h Mark Duffie re: property
return 0.20
Debrn Denison Cantor. . . 1.00
09/30/98 Co pic s
09/30/98 Postage
Total Time:
.prlcir Balance Due:
Services this Period:
Disbursements:
$
$
$
$
1.00 hrs,
Current Trust nulance: $
0.00
AMOUNT NOW DUE:
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Amount
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40.00 'J'
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20.00;;;r
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