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Home My WebLink About01-05077' t ' ~ IN THE COURT OF COMMON PLEAS ROBERT L. KECK, JR., Plaintiff VERSUS PdTRT(`Td d T7F!`K~ Defendant N O. 2001-5077 CIVIL DEGREE IN D[VORCE AND NOW, , `Y _, IT IS ORDERED AND DECREED THAT ROBERT L. KECK. JR. , PLAINTIFF, AND PATRICIA A. KECK ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE. „, is Ati ROBERT L. KECK, JR., Plaintiff v. PATRICIA A. KECK, Defendant PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: by certified mail, restricted delivery on Defendant on September 1, 2001 (see Affidavit of Service filed September 6, 2001). 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff: December 10, 2001; by the Defendant: December 8, 2001. 4. Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff: December 10, 2001; by the Defendant: December 8, 2001. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-5077 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE 5. Related pending claims: None. LAW OFFICES SNELBAKER. BRENNEMAN & SPARE SNELBAKER, BRENNEMAN & SPARE, P. C. Date: Q~Z, ~~i, v`i+~+u~ By: Attorneys for Plaintiff ~ G t:~ ~ ._. ~m -p `rjj ;-} ~ _ __ ~~' ~ _ -'~7 ~ '~ G'~= ~ . ( . , ` S `'"~ C t,a N ~7 ROBERT L. KECK, JR., Plaintiff v. PATRICIA A. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- Sd~~ 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. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, P.C. LAW OFFICES SNELBAKER, I~~/~~~ ~ 4' BRENNEMAN & SPARE By Attorneys for Plaintiff ROBERT L. KECK, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2001- ~~`7'7 CIVIL TERM CIVIL ACTION -LAW PATRICIA A. KECK, Defendant IN DIVORCE COMPLAINT COUNT I -DIVORCE 1. Plaintiff ROBERT L. KECK, JR. is an adult individual residing at 128 E. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant PATRICIA A. KECK is an adult individual residing at 4600 Warrington Avenue, Apartment 2, Mechanicsburg, Cumberland County, Pennsylvania. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on February 9, 2001 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction since the date of the marriage averred in Paragraph 4, above. 6. Neither party is a member of the armed forces of the United States of America. LAW OFFICES SNELBAKER. BRENNEMAN & SPARE 7. The Plaintiff avers as the grotmds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. The Plaintiff requests this Court to enter a decree of divorce. WHERF.,FORE, ROBERT L. KECK, JR. requests this Court to enter a Decree of Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and Defendant. SNELBAKER, BRENNEMAN & SPARE, P.C. By. ~/~~~9J'~Gi~ Keith 0. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717)697-8528 Date: August 27, 2001 Attorneys for Plaintiff Robert L. Keck, Jr. LAW OFFICES _,)- SNELBAKER. 1 BRENNEMAN & SPARE VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I LAW OFFICES SNELBAKER. BRENNEMAN & SPARE understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4909 relating to unsworn falsification to authorities. ~~a ~~~~ Date: ~~ ~~~ Robert L. Keck, Jr. III ROBERT L. KECK, JR., IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001- CNIL TERM CIVIL ACTION -LAW PATRICIA A. xECx, Defendant : IN DIVORCE AFFIDAVIT I, ROBERT L., KECK, JR., being duly sworn according to law, depose and say: L I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. `~i ~// Robert L. Keck, Jr. (Plaintiff) LAW OFFICES Date: ~~~ ?~Q~ SNELBAKER. ((( BRENN6MAN & SPARE c~ ~ ~ c ~ ~ `~ ~ ~ w ~ g ~-~ u \~ ;~ `.~. ~yo ^a J ~s ,~ '~ _~ ~::~ ~~ ~. jI ROBERT L. KECK, JR., IIv' THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. N0.2001-5077 CIVIL TERM CIVIL ACTION -LAW PATRICIA A. KECK, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND SS. Keith O. Brenneman, Esquire, being duly sworn according to law deposes and says: that LAW OFFICES SNELBAKER. BRENNEMAN 2~ SPARE he is a principal in the law firm of Snelbaker, Brenneman & Spare, P. C., being the attorneys for Robert L. Keck, Jr., Plaintiff in the above captioned action in divorce; that on August 31, 2001, he did send to Defendant Patricia A. Keck by certified mail, return receipt requested, restricted delivery, a duly certified copy of the Complaint in Divorce which was filed in the above captioned action as evidenced by the attached cover letter of the same date and Receipt for Certified Mail No. 7000 1670 0008 5047 3077; that both the Complaint and cover letter were duly received by Patricia A. Keck, the Defendant herein, as evidenced by the return receipt cazd for said certified mail dated September 1, 2001; that a copy of the aforementioned cover letter dated August 31, 2001 is attached hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt for Certified Mail and the Domestic Return Receipt are attached hereto and incorporated by reference herein as "Exhibit B' ;and that the foregoing facts are true and correct to the best of his knowledge, information and belief. Keith 0. Brenneman Sworn to and subscribed before me this 5~' day of September, 2001. Notary Public Motarfal seat 8t~sagbnt~ttnLgg. Z~ch, PJotery Pubfi~ CnnurBsalonE xW . ~ ~nDe4 pe~~Nante P~eeeciatWn W ttlotanes -2- LAW OFFICES SNELBAKER. BRENNEMAN & SPARE SNELBAKER, BRENNEMAN F3 SPARE A PROFESSIONACtORPORIATION ATTORNEYS AT LAW 44 WEST MA[N STREET MECHANICSBURG, PENNSYLVANIA V055 RICHARD C SNELBAKER KE7iH O. BRENNEMAN PHILIP H. SPARE 7V-697-8528 P. O. BOX 318 fAC57MILE 017) 697-7681 Patricia A. Keck Apartment 2 4600 Warrington Avenue Mechanicsburg, PA 17055 August 31, 2001 Re: Keck vs. Keck No: 2001-5077, C.C.P. Cumberland County, Pennsylvania Dear Ms. Keck: Enclosed please find a certified copy of a Divorce Complaint which was filed August 30, 2001 noting that a divorce action has been initiated against you. Yours truly, Keith 0. Brenneman KOB:jjc Enclosure cc: Robert L. Keck, Jr. (w/enclosure) BY CERTIFIED MAIL, RETURN RECEIPT REQUESTED, RESTRICTED DELIVERY PARCEL NO: 7000 1670 0008 5047 3077 EXHIBIT A LAW OFFICES SNELBAKER. BRENNEMAN & SPARE .. r M1 f~ 0 c.re,„ :~~.. it ~ ; fi. m "t.a -. 17"a e ~ ~ Postage $ , ~ ~ ~~ b ~ Certified Fee ~ ~ .,I PosirTark ~ Return Receipt Fee E d R i d 1 50 ~ Hs~ ~j O ( n osement equ re ) • lS r 0 O Restrictetl Delivery Fee (Endorsement Required) 3 • ZO ~~i ~~ ~ T l P O '' 3 `~ .__. ~F ~ ota ostage & Fees I $ ; ~ "' ~ Sent To Patricia A. Keck - ' ' p ----_ ................_____.......-.._--------__. Street, Apt. No.; or Po Box No. -------_--_----_-_ _ ~~~.. _ Yn~ `~ P~ ~ '---, 4fi00_ Warrin ton, Avenue- GtyStste Z/P+4 'j~ec~ anicsbur - p_ __ - '~'~ ~~~~~ k.`-2------ , i g, ~~ CA~iplete items 1, 2, and 3. Also complete iQirm 4 if Restricted Delivery is desired. t J~}nt your name and address on the reverse so that we can return the card to you. ^ ~YacMthis card to the back of the mailpiece, or on the front if space permits. A. Received by (Please Print . s( 1. Article Addressed to: Patricia A. Keck Apartment 2 4600 Warrington Avt~riue f Mechanicsburg, PA 17055 C. Sig u e //9 X ~~ / ^ Agem ^ Atldrei D. Is delivery adtlress different from item t 7 ^ Yes If YES, enter delivery adtlress below: ^ No 3. Service Type ~7 Certified Mail ^ Express Mail ^ Registeretl ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (F~rtra Feel ~ Yes 2. Article Number (Copy from service label) PS' FOrrlll ~~$~ ~, ,July 1999 ~ Domestic ~le[urn Receipt ~ ~ ~ 10259500-M-0952 EXHIBIT B ROBERT L. KECK, JR., Plaintiff v. PATRICIA A. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2001-5077 CIVIL TERM CNIL ACTION -LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 30, 2001. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I verify that the statements made in this Affidavit are true and correct. I understand LAW OFFICES SNELBAKER, BRENNEMAN & SPARE that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: 1 /~~'lI~G~Z l U, ~lJ 1 `~~` '~' "' i~y/J Robert L. Keck, Jr. (Plaintiff) .S . L s : :. .....~ ~ ~ . . . ~ C7 r ' `r~ , ' ~~ ~ , J - ~4-' C7 C`V ~n .:x ~ ~~ .,W -C ROBERT L. KECK, JR., Plaintiff v. PATRICIA A. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2001-5077 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIV ORCE DECREE UNDER SECTION 33010 OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this affidavit are true and correct. I understand LAW OFFICES SNELBAKER, BRENNEMAN & SPARE that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: 1~~L~~rt /~, Jaa / ~~ Robert .Keck, Jr. (Plaintiff) C> ~~ ( i C. -- -. ~~_ ~[_ N -;"i ~~i- f~i :...)~.~~ .-~ i°'" ~ C W ='{'^ r' ~ ~'= '~ ' - i~ ROBERT L. KECK, JR., Plaintiff v. PATRICIA A. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2001-5077 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE I. A complaint in divorce under Section 3301(c) of the Divorce Code was tiled on August 30, 2001. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I verify that the statements made in this Affidavit are true and correct. I understand LAW OFFICES SNELBAKER, BRENNEMAN Pl SPARE that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: .~77- ~~~ ~ ~ ~, ~K Patricia A. Keck (Defendant) c, ~ c~~ - ~ ~~ ! Z s' zd.7 -n -- ~~ ~~ ~ } ~ ~ ; ~t_.. ~ __,~ ' 1>C. , _..~ '% j ~ y "< ROBERT L. KECK, JR., Plaintiff v. PATRICIA A. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2001-5077 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c~F THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. 4. I verify that the statements made in this affidavit are true and correct. I understand LAW OFFICES SNELBAKER. BRENNEMAN & SPARE that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: f a- 8 - D~ ~Aa~ D,~r'.L? Patricia A. Keck (Defendant) <-, - -, - _... ~ ` ~, ., -v~~. ~~ ---~ ~, ~ , - ~,=-, cc~ -? c, -i ~ A d" "t