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Home My WebLink About03-0842TEDDY J. KEPPLEY, Plaintiff V= SUSAN M. KEPPLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- ~-4/,,,~ CIVIL TERM CIVIL ACTION-LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. VVhen the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone: (717) 249-3166 TEDDY J. KEPPLEY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2003- ¢~f2.-- CIVIL TERM SUSAN M. KEPPLEY, Defendant CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Teddy J. Keppley, an adult individual who currently resides at 147 South East Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Susan M. Keppley, an adult individual who currently resides at 338 East Garfield Street, Shippensburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on June 19, 1991 in Maryland. There have been no prior actions of divorce or for annulment between the o 5. parties. 6. 7. The marriage is irretrievably broken. The Plaintiff has been advised of the availability of counseling and that he may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. Respectfully submitted, O'BRIEN, BARIC & SCHERER DATE: ~.. 2. ~'. O"J Michael A. Scherer, Esquire I.D. # 61974 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.dir/domesticlkeppleyldivorcecomplaint.pld VERIFICATION The statements in the foregoing Complaint are based upon information which has been assembled by my attorney in this litigation. The language of the statements is not my own. I have read the statements; and to the extent that they are based upon information which I have given to my counsel, they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. DATE: 2.2q. o3 TEDDY J. KEPPLEY, Plaintiff SUSAN M. KEPPLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-842 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODI- 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 25, 2003. Susan M. Keppley was served by certified mail on March 1, 2003. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Susan M. Kepl~e~, ~f TEDDY J. KEPPLEY, Plaintiff SUSAN M. KEPPLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-842 CIVllL TERM CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(c) OIF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was =iled on February 25, 2003. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 4. I understand that I may lose rights concerning alimony, division of ~roperty, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: ¢;/T:~:ldy J'. ~e"pple~]"' TEDDY J. KEPPLEY, Plaintiff SUSAN M. KEPPLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-842 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE CERTIFICATE OF SERVIC~E I, Michael A. Scherer, Esquire, attorney for the Plaintiff in the above-captioned divorce action, do hereby certify that I served a certified copy of the Complaint in Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card. DATE: April 14, 2004 O'BRIEN, BARIC & SCHERER mhaelA. Scherer, Esquire · Complete items 1, 2, and 3, Alao . ~em. 4 if REwt~cted De~lvE~ 18 dee,lind, = ~¢l~laYt~wr~neme and add~ ~ the mve~ -~~/~ 7001 2S10 0006 5,,91 3794 PS Fo~ 3811, A~ust 2001 TEDDY J. KEPPLEY, Plaintiff SUSAN M. KEPPLEY, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003-842 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ~PRAECIPE TO TRANSMIT Rr';CORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the divorce code. (b) (1) of the divorce code (2) 4. 5. 2. Date and manner of service of the complaint: Via certified mail, restricted delivery upon the Defendant on March 1, 2003. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required under Section 3301(c) of the divorce code: by the plaintiffApril 15, 2004 by the defendant - April 7, 2004 ' Date of execution of the plaintiff's affidavit required by Section 330 l(d) N/A Date of service of the plaintiff's affidavrit upon the defendant N/A Related claims pending Complete either (a) or (b) NONE (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's waiver of notice in Section 3301(c) divorce was filed with the Prothonotary:_ May 3, 2004 Date defendant's waiver of notice in Section 3301(c) divorce was filed with the Prothonotary:. April 14, 2004 Michael A. Scherer, Esquire Attorney for Plaintiff', T~ddy J. Keppley IN THE COURT OF CONIN1ON PLEAS OF CUMBERLAND COLIN'FY STATE OF TEDDY J. KEPPLEY, Plaintiff VERSUS SUSAN M. KEPPLEY, Defendant PENNA. N o. 2003-842 CIVIL DECREE IN DIVORCE AND NOW,~ TEDDY J. KEPPLEY DECREED THAT AND SUSAN M. KEPPLEY ~1~1~ , IT IS ORDERED AND , PLAINTIFF, ., DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLI_OWiNG CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE BY THE COURT: ATTEST: _ - ~~ PROTHONOTARY