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Home My WebLink About99-03455?r O? CT v W ^ V w Q z u. > z C o o>P J 3 w u j w (L S w ^ } 0, UJ 'Q ^ m v? ? c Q s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. N c>.....9.9.-.39.5.5 . .................. 19x9 DECREE IN DIVORCE C-t AND NOW, ..... °^ .. ..3...... , 1955.... , it is ordered and decreed that ... Mary..a., x.Biter .............................. plaintiff, and ...David. c..Ke.iter ..................................... 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. ................................................... ...... y .............................................. F R y r t Attest: J. /l aProlhonolary? ? :?i .P. .?. t?; .P, e: :P. .P. :?:• .P. .P: :P, s. .?: t?, .e. ?:`?P. sir. •?a •x. •w:• •W> 40 !q ,P. w:• W io it i iy 1 1.2 -Q-3. MARY B. KEITER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 99-3455 DAVID C. KEITER, Defendant IN DIVORCE 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: June 25, 1999 Defendant signed an Acceptance of Service which was filed on August 17, 1999. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by Plaintiff: November 15, 1999; by Defendant: November 15, 1999. (b)(1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiffs Affidavit upon the respondent: N/A. C 4. Related claims pending: None 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transmit record; a copy of which is attached: N/A (b) Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 30, 1999. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: November 30, 1999. c.ix: G::r X61 L ) Cl- ? (I) U W LL. Lo U. ?J v c ? w ZZ?o ww.. Vag ?- C ? c u ^ m Q gy " ? c cam. ?j' T Iv CU (? VU ` / a ?- I V U1 w cj? lJ? ?J r f7 ?A ^G MARY B. KEITER, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. NO. CIVIL ACTION DAVID C. KEITER, 99_.3ySS Defendant : IN DIVORCE 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, Cumberland County Courthouse, High and Hanover Streets, Carlisle, Pennsylvania. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas pmanda y la notificacion. sUstedtdebe prese'ntar una ap(ari n cia escrita o en persona ona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede entrar una orden contra usted sin previo puede perder dinero os us p ope r dades o a otros de echos pmportanates para usted demanda. Usted LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAIv1ENTE. SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MARY B. KEITER, Plaintiff V. DAVID C. KEITER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 99- 39,s-S' au I 1i.,.... IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE AND NOW comes the above Plaintiff, Mary B. Keiter, by her attorney, Kathleen Carey Daley, Attorney at Law, and seeks to obtain a decree in divorce from the above-named Defendant, upon the grounds hereinafter set forth: 1. The Plaintiff, Mary B. Keiter, is an adult individual who resides at 216 Herr Street, Harrisburg, Dauphin County, Pennsylvania 17102. 2. The Defendant, David C. Keiter, is an adult individual who resides at 429 15th Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 12, 1979 in York, York County, Pennsylvania. 5. 6. The Plaintiff and Defendant are both citizens of the United States of America. There have been no prior actions in divorce between the parties. 7. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies. R. Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. 9. The causes of action and sections of Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301(d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on February 26, 1997. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony. I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. By: -rryB.1 ?? (' Mary B. erter, Plaintiff Date: 4011119 _ By: &"? thleen Carey Daley, Attorney No. 30078 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorney for Plaintiff S N ^ W m LO LL. O ??+^ F zz Va^ N 0 ^ v L U C J D Q N ® C x Y' C N i? MARY B. KEITEF, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. NO. 99-3455 DAVID C. KEITER, Defendant IN DIVORCE ACCEPTANCE OF SERVI I, David C. Keiter, do hereby accept service of the true and correct copy of the Complaint in Divorce in the above case. Date: June 25, 1999J? •/G7 DAVID C. KEITER MARY B. KEITER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW V. NO. 99-3455 DAVID C. KEITER, Defendant IN DIVORCE A Complaint in Divorce under §3301(c) of the Divorce Code was filed on June 8, i999, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 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.A. §4904 relating to unswom falsification to authorities. Date: 114 f By. ... '?4 e" 4??, MARY B. IT ,R Plaintiff SocialSecurityNo. II6" f/-,f ?'e -7 LY Lr' Lr. ? Qc: .. U } ..' t u ' L: L MARY B. KEITER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA I{( CIVIL ACTION - LAW V. NO. 99-3455 f DAVID C. KEITER, j Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST EN'T'RY OF A DIVORCE DECREE UNDER &3301 (C) OF THE DIVORCE CODE I. 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. 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.A. §4904 relating to unswom falsification to authorities. ? Date: 11 /f5/91 By:4/06 MARY B ITER, Plaintiff t L:J Cl?iU la. u " rn U MARY B. KEITER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW V. NO. 99-3455 DAVID C. KEITER, Defendant IN DIVORCE A Complaint in Divorce under §3301(c) of the Divorce Code was filed on June 8, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 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.A. §4904 relating to unsworn falsification to authorities. Date: I Sam/ 1 f By: zlm C . e_t & DAVID C. KEITER, Defendant SocialSecurityNo. /I /- yV - G 5'4 L L• ? l N cJ.t r ?^ MARY B. KEITER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. DAVID C. KEITER, NO. 99-3455 Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE 11NDER §3391((" l OF TAF DIVORCE runs 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. 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.A. §4904 relating to unswom falsification to authorities. Date: it S" By: -Lz C• Kum DAVID C. KEITER, Defendant G ts) U7 C y T 4'CS °•- 7 c_ ?,; i -?- ?6 ?? ? ? ? ? ? ? ? fiy.. ? 2/ MARY 13, KEITER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. DAVID C. KEITER, Defendant NO. 99-3455 IN DIVORCE ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Plaintiff, in the above matter, having been granted a Final Decree in Divorce on the 23 rd day of December, 1999, hereby elected to retake and hereafter use her maiden name of Mary Helen Bruno, and gives this written notice avowing her intention in accordance with the provision of 54 Pa.C.S.A. §704(a). Date: k Mary Bru Biter TO BE KNOWN AS: Mary H 06n Bruno COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. AFFIDAVIT On the (?)41? day of ?L 1999, before me, a Notary Public, personally appeared Mary Bruno Keiter, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARIAL SEAL PATRIMA A. PATTON, Notary Pubitc Lower Paxton Twp., Dauphin County