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HomeMy WebLinkAbout07-1160,- . le ee-/ /-D le- - V. X e- C.? kc. C;>,- 4"J--'00 0,1P 6DA1.Iw0111 i'IGc?S ?u.?•?Oes (a.?d Cou r-4-1 Pe-4tis,1i-&,J x La--se- N+4.4-6er'- U7 -1160 G1u, I -t' f r& 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 Street, 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. Court Administrator, Fourth Floor Cumberland County Court House Carlisle, PA 17013 (717) 240-6200 In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Leap Keo ) Case Number l' 6 d `'f i +? rn. Plaintiff V. Judge: Anna K Keo Defendant Complaint for Divorce This suit is brought by Leap Keo, the Plaintiff, Pro Se, Social Security #: 549-79-4929, Drivers License/State ID #: 28997022, age 29 years old, who resides at: 418 Stonehedge Ln, Mechanicsburg, Pennsylvania, 17055 with a home phone number of: 717-605-7045. Defendant is Anna K. Keo, Pro Se, Social Security #: 576959964, Drivers License/State ID #: H00440665, age 22 years old, who resides at: 47513 Apau Loop, Kaneohe, Hawaii, 96744 with a home phone number of: 808-428-0348. 1. RESIDENCY: The Plaintiff has been a resident of the State of Pennsylvania for the preceding 6 (six) months and a resident of the county in which this Complaint for Divorce is filed for the preceding 10 (ten) days. 2. MI .ITARY STATUS: The Defendant is NOT active in the United States Military. The Plaintiff is active in the United States Military and is familiar with the provisions of 50 App. Section 520, Civil Relief Act of 1940. Further, after careful consideration, the Plaintiff waives all rights and privileges, including appointment of counsel, pursuant to the Soldier's Civil Relief Act of 1940. 3. SERVICE OF PROCESS: A Waiver of Citation will be filed by the Defendant, therefore, no service is necessary at this time. 4. JURISDICTION: The Court has the required jurisdiction to hear this case. Neither party has ever been involved in any other domestic relations proceedings involving the other party in this or any other jurisdiction. 9, ' „ 5. MARRIAGE: The parties were married on November 15, 2002 in the city of Honolulu, in the state of Hawaii, and separated on or about, February 28, 2006, at which time they separated and ceased to live together with the intent to terminate the marriage. An official marriage license is attached to this Complaint for Divorce for reference. 6. GROUNDS: Irretrievable breakdown of the marriage and the spouses intend to file affidavits that they consent to the divorce. 7. PREGNANCY: The Defendant is not currently pregnant. 8. CHILDREN: There are no minor children born or legally adopted of the marriage. 9. PROPERTY AND DEBT: The property and debt, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. 10. RETIREMENT ACCOUNT The retirement accounts, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. 11. SPOUSAL SUPPORT: The spousal support, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. 12. HEALTH INSURANCE: The health insurance, and other related issues, will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. 13. TAX ISSUES: The tax issues will be settled by a formal written Marital Settlement Agreement, which will be submitted to the Court. 14. PROTECTIVE ORDERS: There are no protective orders between the Plaintiff and Defendant. 15. PRAYER: The Plaintiff respectfully requests this Honorable Court to grant this Divorce pursuant to Section 3301 (c), or on the alternative, Section 3301 (d) of the Divorce Code. 16. REPRESENTATION The Plaintiff has chosen to act as his own attorney in a pro se fashion, and understands that he has the legal right to representation by an attorney. He fully understands his rights and consider the terms of the attached Marital Settlement Agreement to be fair and reasonable. 17. VERIFICATION I verify that the statements made in the Complaint for Divorce are true and correct. I understand that false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. ?. .. }1 Date: 2 Ff 69V 9Lf , zo u7 L 05 ,E r° 1L e C) Print Name (Plaintiff, Pro Se) ature laintiff, Pro Se) Mailing Address: 418 Stonehedge Ln, Mechanicsburg, Pennsylvania, 17055 Phone: 717-605-7045 U Pl- Q p? ? Q I Q d IS I-N n na t? 7 b ., r? x rTIM cn -..i -< In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Leap Keo Plaintiff V. Anna K. Keo Defendant Acceptance of Service Term, 2 Case Number: L)7-1160 I, Anna K. Keo, Defendant in the above-captioned action depose and say that on this date I hereby accept service of the Complaint in Divorce and Notice to Defend and Claim Rights with Notice of Availability of Counseling. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date:I e 0'? - _. "k ?zo Print Name (Defendant) Signature (Defendant) Mailing Address: 2122 Lime St. Apt 303, Honolulu, Hawaii, 96826 Phone: 808-429-7173 i:RCE OF 41POR-O?-IMIINOTARY 2N9 SEP y-4 PM 20 4 1 ?. ?,OUNTY WANIA 2 In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Leap Keo Plaintiff V. Anna K. Keo Defendant Term,2 6 Case Number: © -? - 11-6 Affidavit of Verification THE STATE OF: Pennsylvania COUNTY OF: Cumberland BEFORE ME, Leap Keo, the undersigned authority and the Plaintiff in the above referenced case, on this day personally appeared who, being by me duly sworn, upon oath says: My name is: Leap Keo Social Security #: 549-79-4929 Driver's License/ State ID #: 28997022 My mailing address is: 418 Stonehedge Ln, Mechanicsburg, Pennsylvania, 17055 Phone: 808-429-0694 The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my knowledge, information, and belief, and that I am authorized to make this affidavit. Date: / N oOv 6 v S T . 2" a- . Print Name (Plaintiff) ure (Plaintiff) SWORN TO AND SUBSCRIBED BEFORE ME by the said Leap Keo, Plaintif f on this August 14th 2008 to certify which witness my hand and seal of office. 4;-%? 1 Notary ublic, State of Pennsylvania Notary Seal My commission ex?i?es. YLVANIA MM Notarial Seal Rosa A r iz. NOVIVy Public Cadisie Ebro, G. rnuerland County My Commission Expires Nov. 8, 2009 Member, Pennsylvania Association of Notaries RLED-OffICE OF THE PR 1tHOWTARY 2009 SEP -4 PM Z: 37 PEWS t,V'AN A rc, 1? In the Court of Common Pleas, Cumberland County, Pennsylvania Leap Keo Plaintiff In Re the Marriage of: V. Term, 2 Case Number: G 7 - 116 0 Anna K. Keo Defendant Acknowledgement (Plaintiff) THE STATE OF: Pennsylvania COUNTY OF: Cumberland On this / V ` day of , 2 o a & , before me, a Notary Public, the undersigned officer, personally appeare Leap Keo, known to me to be the person whose name is subscribed to this written instrument, and acknowledge that (s)he executed the same for the purposes therein contained. A Complaint for Divorce under Section 301 (c) of the Divorce Code was filed on / It & u6 Y S T , Z .,C2 fir . I , the Plaintiff, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken and nintey (90) days have elapsed from the date of the filing of the Complaint for Divorce. All information contained within the attached documentation is true and correct to the best of my knowledge, information and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Settlement Agreement documentation. Date: /V A v-,A jc3 r 7-- O ?- L 46 A /' 1z c-a Print Name (Plaintiff) nature laintiff) F *•- SWORN TO AND SUBSCRIBED BEFORE ME by the said Leap Keo plaintiff on this Aug„Gr 14th moo to certify which witness myhand aandd seal of office. Notary Public, State of Pennsylvania Notary Seal My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Rosa A Ortiz Notary Public Cariisie Soro. Cumoerland County My Commission Expires Nov. 8, 2009 Member, Pennsylvania Association of Notaries FILED-OffiGE OF 1 ,RC1THNOTARY 2009 SEP -4 PM 2: 37 l + BE -ri'4- o ? OUNTY € ENI YLVAM In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Leap Keo Term, 2 Plaintiff V.. Anna K. Keo Defendant Case Number: O 7 - //tf 6 Acknowledgement (Defendant) THE STATE OF: Hawaii COUNTY OF: Honolulu On this day of , 2 , before me, a Notary Public, the undersigned officer, personally appeared Anna K. Keo, known to me to be the person whose name is subscribed to this written instrument, and acknowledge that (s)he executed the same for the purposes therein contained. A Complaint for Divorce under Section 301 (c) of the Divorce Code was filed on I , the Defendant, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken and nintey (90) days have elapsed from the date of the filing of the Complaint for Divorce. All information contained within the attached documentation is true and correct to the best of my knowledge, information and belief. It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth within said Marital Settlement Agreement documentation. Date: q:% 1,1'\cj ICW1 c Q*'a Print Name (Defendant) N?DL V-?-* Signature (Defendant) -2 v to BEFORE NE by th?t? O AND SUBSCRIBED on this ' 5W,QRN T ;e 0,ny an and seal of office. Votary CC) My commission expires: ON,An?????fr s '°(J %Cl Off' THE o LEP"rO-OTARY 2 SEP -4 PM 2: 3 7 i ?+? /1j ?•` f- k ?iJ WUNTY \f? f T In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Leap Keo Case Number: O 7- l l 6 v Plaintiff V. Anna K. Keo Defendant Judge: Marital Settlement Agreement This agreement is made on _ v r L , ao o , between Leap Keo, the Plaintiff, with a social number of 549-79-4929, who lives at 418 Stonehedge Ln, Mechanicsburg, Pennsylvania, 17055 (home phone: 808-429-0694) and the county of Cumberland and Anna K. Keo, the Defendant, with a social security number of 576959964, who lives at 2122 Lime St Apt 303, Honolulu, Hawaii, 96826 (home phone: 808-429-7173) and the county of Honolulu. The Plaintiff and Defendant may from time to time throughout this agreement, individually and collectively, be referred to as "Party" or "Parties". The Plaintiff is currently employed by USMC, which is located at, 5450 Carlisle Pike, Mechanicsburg, Pennsylvania, 17055 with a telephone number of 717-605-8591. The Defendant is currently not. employed. 1. Recitals: The parties are making this agreement with reference to the following facts: The parties were married on November 15, 2002 in the city of Honolulu, in the state of Hawaii, and separated on or about, February 28, 2006. As a result of serious disputes, conflict of personalities, and unique goals and differences, the parties honestly believe that the marriage is irretrievably broken and that there is no possible chance for reconciliation. For this reason each party desires to settle fully and finally all aspects and rights, by this agreement, of the marital affairs including, but not limited to; Property and Debt Distribution, Retirement/Pension/Profit Sharing/401k Accounts, Spousal Maintenance, and Income Tax Returns. There are no children born or legally adopted of the marriage under the age of eighteen (18). The parties each now intend by this agreement to settle fully and finally all of their respective rights and obligations arising out of or related to the marriage that otherwise could be adjudicated in the above captioned case number. There is no other pending action filed by either party regarding the dissolution of the marriage. The date of execution of this agreement is the day on which the agreement is signed by both parties. Any transfer of property, funds, debts and/or documents pursuant to the agreement shall be made on the date of the execution of this agreement, if not already done so, unless otherwise specified in this agreement. The parties both agree to lead separate lives, and, except for the duties and obligations imposed and assumed under this agreement, each shall be free from interference and control of the other as fully as if he or she were single. The parties each agree not to molest, interfere with, or harass the other. 2. Property and Debt Distribution: As of February 28, 2006, the parties have each possessed his and her marital and non-marital property and have been responsible for the marital and non-marital (separate) debt that will be described below. The parties agree that the following marital property shall be the sole and separate property of Leap Keo, the Plaintiff, and Anna K. Keo, the Defendant transfers and quitclaims any interest that she may have in this marital property to the Plaintiff: 2002 Toyota Tacoma (VIN# 5TEWN72N52Z893993) The parties agree that the following marital property shall be the sole and separate property of Anna K. Keo, the Defendant, and Leap Keo, the Plaintiff transfers and quitclaims any interest that he may have in this marital property to the Defendant: 98 Toyota RAV 4 (VIN# JT3GP10V5W7032183) The parties agree that Leap Keo, the Plaintiff, shall pay and indemnify and hold Anna K. Keo, the Defendant, harmless from the following marital debts: Navy Federal Credit Card: 4060 0046 8050 (Outstanding Balance: $6,393) Vehicle Loan: $19,583 The parties agree that Anna K. Keo, the Defendant, shall pay and indemnify and hold Leap Keo, the Plaintiff, harmless from the following marital debts: Navy Federal Credit Card Account: 4060-9560-0364-5662 (Balance:$3,500). School Loan: $72,000 The parties agree that the following non-marital (separate) property shall be the sole and separate property of Leap Keo, the Plaintiff, and Anna K. Keo, the Defendant transfers and quitclaims any interest that she may have in this non-marital (separate) property to the Plaintiff: None The parties agree that the following non-marital (separate) property shall be the sole and separate property of Anna K. Keo, the Defendant, and Leap Keo, the Plaintiff transfers and quitclaims any interest that -he may have in this non-marital (separate) property to the Defendant: None The parties agree that Leap Keo, the Plaintiff, shall pay and indemnify and hold Anna K. Keo, the Defendant, harmless from the following non-marital (separate) debts: None The parties agree that Anna K. Keo, the Defendant, shall pay and indemnify and hold Leap Keo, the Plaintiff, harmless from the following non-marital (separate) debts: None The parties both hereby represent and warrant that as of the date of this agreement, they do not possess any property or interests in property other than the items listed in this agreement; and that the items set forth and listed in the agreement constitute full and complete disclosure. In addition to the items listed in this agreement, if any undisclosed property or interests in property is discovered subsequently, and a court of competent jurisdiction determines it to be marital or community property of the parties, such discovery and determination shall not invalidate this agreement but, the property or the interest in it shall at the election of the discovering party (i) be divided equally or equitably in kind or (ii) be accounted for by the party in possession who may pay to the discovering party a sum of money to offset an equal or equitable portion. The parties both hereby represent and warrant that except for the debts and obligations set forth and listed above, each has not incurred any other outstanding debt or obligation on which the other may become liable, nor has either party incurred any obligation that could henceforth be enforced against any asset held or received pursuant to this agreement. In the event that any outstanding debt or obligation of any kind has been incurred by either party, other than those listed above (and is hereafter asserted against the other), the party actually incurring the debt or obligation shall assume and be solely responsible for paying it and shall hold the other party harmless from all claims with respect to the debts, obligations, and expenses with respect to those debts. In the event that the other party becomes a debtor in any bankruptcy or financial reorganization proceeding of any kind while this agreement is in effect, that debtor party waives any and all rights to any property held by the other party which is in fulfillment of this agreement. The debtor party will also convey to the other party that the bankruptcy or financial reorganization proceeding is going to take place. The parties acknowledge and agree that the credit history established by them during their marriage shall be deemed to have the credit history of both parties, not withstanding ordinary practices of creditors and credit reporting agencies that may have reported such credit history in the name of one party. Both parties agree to cooperate and execute any documents as may be required to enable each other to provide to prospective creditors the full credit history of the parties that was established during the marriage. The parties each represent to the other that from the date of this agreement each party shall not charge or incur or cause to be incurred any liability or obligations based on the credit or name of the other. Each of the parties shall do whatever is necessary to close immediately all joint accounts. The parties each forever waive any right to inherit from the other and the right to receive any property on the death of the other, except as a beneficiary of any life insurance policy, by reason of a will, codicil, or republication of will by the other party executed subsequent to the date of this agreement. The parties each waives all right to act as administrator of the other party's estate and all right to request or petition for the appointment of any person to serve as such representative or to act as the executor of the other's will, unless expressly named in a will, codicil, or republication of will by the other party executed subsequent to the date of this agreement. 3. Marital Home: There is no marital home of this marriage. 4. Retirement Accounts/Pensions1401ks/Profit Sharing Plans: The parties each waive all claims, present and future to the other's pension benefits, retirement funds, 401k's, profit sharing plans and accounts of the like. 5. Spousal Maintenance: After careful consideration of the circumstances and all the other terms of this agreement, the parties agree to waive any rights or claims that he or she may have now or in the future to receive ant rehabilitative or permanent spousal maintenance from the other party. The parties both agree each will be responsible for his and her own health and medical insurance coverage. 6. Income Tax Returns: The parties agree that they will file separate federal and state tax returns for the calendar year in which this agreement is made into effect. The parties both agree that they will cooperate in the filing of any necessary tax returns. For each calendar year after the year this agreement is made into effect, each party shall file separate federal, state and local income tax returns, in which each shall include and report all of his or her separate income and shall pay all income taxes due. The parties each agree to notify the other promptly in the event the IRS or any state or local taxing authority provides notice of an audit, deficiency, refund, or the adjustment regarding a tax return that was jointly filed or that should have been jointly filed. The party receiving such notice from a taxing authority shall provide a copy of the notice to the other party within 20 days of receiving it. The parties further agree to cooperate fully with the other in any claims for refunds or in defending against any deficiencies that may be determined with respect to joint income tax returns filed (or to be filed). This includes, without limitation, the making, executing, and filing of amended income tax returns; applications for refunds, protests, and other instruments; and documents as may be required. The costs and expenses for such will be divided equally between the parties. 7. Professional Fees and Costs: The parties have not acquired any professional service fees which they desire to be recognized, mentioned, or distributed by this agreement. 8. Advice of Counsel: The parties each acknowledge that they have the legal right to representation by separate attorneys. The parties each fully understand his and her rights and the, contents of this agreement. The parties each consider the terms of this agreement to be fair and reasonable and each party accepts sole responsibility for any decisions, and potential repercussions of those decisions, which are presented as part of this agreement. 9. Mutual Releases: Each party hereby releases the other from any claim of action that either may have against the other for any reason occurring prior to this agreement, whether that claim is founded in contract, tort, or any other basis. 10. Governing Law: The parties agree that this document is intended to be a full and an entire settlement and agreement between them regarding the marital rights and obligations and that this agreement, and all contents within and attached, shall be interpreted and governed by the laws of the State of Pennsylvania. 11. Entire Agreement: This agreement constitutes the entire and full agreement between the parties. If any clause is held unenforceable or found to be in any way non-executable, or if a court alters or holds unenforceable any clause in this agreement, this shall in no way affect or alter the other clauses in the agreement, which shall remain in full force. No amendment or modification to this agreement or any judgment, decree or order based on it shall be valid unless signed and agreed to by both parties or ordered by the court after a duly noticed hearing. 12. Further Assurances: The parties shall execute and deliver promptly on request any additional papers, documents, and other assurances reasonably necessary in connection with the performance of the obligations set forth in this agreement. In the event that either party fails or refuses to comply with the provisions of this agreement, the failing party shall reimburse the other party for all loses and expenses including, but not limited to, attorney's fees and all costs incurred as a result of such failure. 13. Captions and Interuretations: Paragraph captions have been used throughout this agreement for convenience and reference only and are not intended to be used in the construction or interpretation of this agreement or any of its provisions. No provision of this agreement is to be interpreted for or against any party by virtue of the fact that the provision was drafted by that party or that party's counsel. 14. Submission to Court for Incorporation: This agreement has been drafted and executed with the intention that it be submitted by either party to any court before which a Complaint for Divorce may be pending or initially filed for approval by the court and for incorporation into a Decree of Divorce pursuant to Sections 4104(a)(1) and (3) and 3323(b) of the Divorce Code. 15. Verification/Disclosure: The parties both have reviewed this agreement cooperatively and each party has fully and honestly disclosed to the other the extent of his or her assets, income, and financial situation, and therefore enter into this agreement reliance thereupon. W Attached to this agreement is a completed Domestic Relations Income and Expense Statement for each party to further present to each other and the court his and her current income, expenses, property and debts. 16. Successions: The parties each acknowledge that this agreement, and each provision of it, is expressly made binding upon the heirs, assigns, executors, administrators, representatives and successors in the interest of each party. Signed and dated on / N 4 y 6 , 2Vp---V f . z &W ---I &e ex-2 Print Name (Plaintiff) natur amtiff) ftf-W Print Name (Defendant) 0IM-4 " Signature (Defendant) C- S -ref- Qcoe-ac- Witness #1 Name Witness #1 Signature rr Witness ame fitness # Signature State of Pennsylvania County of um er and SWORN TO AND SUBSCRIBED BEFORE ME by the said Leap Keo & Anna K. Keo On August 14 , 20 08, before me, the undersigned, a Notary Public in and for said State, personally appeared Leap Keo, the Plaintiff, known to me (or proved on the basis of satisfactory evidence) to be the person whose name is subscribed to within the instrument and acknowledged that he executed the same. Witness my hand and official seal. &4A lc-' &T - Notary Public Notary Seal COMMONWEALTH OF PENNSYLVANIA Notarial Seal Rosa A. Ortiz. Nlotary Public Carlisle 13oro, Curooeriand County My Commission Expires Nov. 8, 2009 Member, Pennsylvania Association of Notaries My commission expires: State of County of SWORN TO AND SUBSCRIBED BEFORE ME by the said On _, 20 _, before me, the undersigned, a Notary Public in and for said State, personally appeared Anna K. Keo, the Defendant, known to me (or proved on the basis of satisfactory evidence) to be the person whose name is subscribed to within the instrument and acknowledged that she executed the same. Witness my hand and official seal. Notary Public Notary Seal My commission expires: OF THE PRQTHI MARY 2009 SEP -4 PM 2: 37 PENNSMANLA In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Leap Keo ) Plaintiff ) V. ) Anna K. Keo ) Defendant ) Case Number: b 7- //6 0 Judge: AFFIDAVIT OF CONSENT (Plaintiff) THE STATE OF: Pennsylvania COUNTY OF: Cumberland 1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint for Divorce. 3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the Decree of Divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: Ars S` _2 d y L G"7?'? /C C27 Print Name (Plaintiff) ature laintiff) JEDr?ACETI-I,r,MTA PY 2109 SEP - 4 PM 2: 3 7 I'Li-.+'dU k"'OuNly PENN XVANIA In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Lean Keo Term, 2 Plaintiff V. Anna K. Keo Defendant Case Number: d 7 -//6 b WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE. (Plaintiff) THE STATE OF: Pennsylvania COUNTY OF: Cumberland 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, distribution of debts, lawyer's fees, or expenses if I do not claim them before a Decree of Divorce is granted by the Court. 3.1 understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a copy of the Decree of Divorce 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: Z?Z d c/ l zw P EGG y Print Name (Plaintiff) Si re (Plaintiff) 411-1* rjc vu . ON rarrr 2009 SEP - 4 PM 2' 3 7 PENNSYLVA ':A In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Lean Keo Plaintiff Term, 2 V. Anna K. Keo Defendant Case Number: _ 0 7 " /I 6 d AFFIDAVIT OF CONSENT (Defendant) THE STATE OF: Hawaii COUNTY OF: Honolulu 1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on /c4 a?yri I- 2 z' D 7 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint for Divorce. 3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the Decree of Divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Date: P1b Print Name (Defendant) Signature (Defendant) RF#(E OF THE PPM, CNOTARY 2009 SEP -4 PM 2'. 37 8t:=A) COUNTY PENNSYLVANIA In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Lean Keo Term, 2 Plaintiff V. Anna K. Keo Defendant Case Number: 0 7 ^ / / 6 a WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE. (Defendant) THE STATE OF: Hawaii COUNTY OF: Honolulu 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, distribution of debts, lawyer's fees, or expenses if I do not claim them before a Decree of Divorce is granted by the Court. 3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a copy of the Decree of Divorce 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unswom falsification to authorities. Date: hop P< Print Name (Defendant) N*4A. Signature (Defendant) HLED-WICE OF lif 3MNOTARY 209 SEP -4 PM 2: 3 7 C?? tiLAANb COUNTY PENNMWA 1A W, In the Court of Common Pleas, Cumberland County, Pennsylvania In Re the Marriage of: Leap Keo Plaintiff V. Term, 2 Case Number: y 7 ^ // 6 Anna K. Keo Defendant Praecipe to Transmit Record Kindly Transmit the Record, together with the following information, the Court for entry of a Decree of Divorce: 1. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and Manner of Service of the Complaint for Divorce: 3 Nl ?? , 2?2, by ( ) personal or 04 certified mail. 3. Date of execution of the Affidavit /Consent Waiver required by Section 3301 (c) of the Divorce Code: By Plaintiff: jf !4?fe a, 21 OZ. By Defendant: f ?9 /dry ? rA' 2 v8 . 4. Complete the appropriate paragraphs: (a) Related claims pending... None (b) Claims withdrawn... None (c) Claims settled by agreement of the parties... None (d) State whether any written agreement is to be incorporated into the Divorce Decree. If yes, attach a true and correct copy of the fully executed agreement to the proposed Decree that is submitted herewith: The parties have both signed a Marital Settlement Agreement resolving all of their issues and wish to heave it incorporated into the Final Decree. 5. I certify that the Notice of Intent to File Praecipe to Transmit as required by Rule 1920.42(c) or (d) was mailed on 3 / Af % , 2-#6L, and a copy thereof is attached. I further certify that all other documents required by Rule 1920.42(e) are enclosed herewith. WK Date: .4N azure a stiff) Mailing Address: 418 Stonehedge Ln, Mechanicsburg, Pennsylvania, 17055 Phone: 808-429-0694 FILED-O'VFICE OF 7HE PROTHONOTARY 2009 SEP -4 PM 2: 5 2 3 ML ? i WUNTY NNSYLYMA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lc?r /Z 1?1_D V. /41v ti 111 14. J4" NO. o .7 - 11Z U DIVORCE DECREE AND NOW, .T?.. fc„ iy Lam S , it is ordered and decreed that t r.aP jec , plaintiff, and n.v.? 14 . lzc defendant, are divorced from tho bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order fort' alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (It no claims remain indicate "None.") rt. By the Court, l 09 g . Ilt ?i `71a?Q