HomeMy WebLinkAbout03-3391WAYNE F. SHADE
MARTHA F. KEIFER,
Plaintiff
WILLIAM B. KEIFER, JR.,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
: NO. 03- 3J]/ CIVIL TERM
:
: 1N 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 thil 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
CUMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA 17013
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.
Cumberlmid County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone: 717-249-3166
Wayne/F. Shade, Esquire
Supreme Co. urt No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
WAYNE F. SHADE
Ailomey at Law
53 West Pomfret Saver
Carlisle, Pennsylvania
17013
MARTHA F. KEIFER,
Plaintiff
WILLIAM B. KEIFER, JR.,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
:
: NO. 03- 33q! CIVIL TERM
: IN DIVORCE
COMPLAINT
1.
Plaintiff in this Action in Divorce is MARTHA F. KEIFER, an adult individual
who resides at 3804 Vine Street, Camp Hill, Cumberland County, Pennsylvania 17011.
Defendant is WILLIAM B. KEIFER, JR., an adult individual and citizen of the
United States of America whose last known address is P.O. Box 194, Austin, Potter
County, Pennsylvania 16720.
Plaintiff has been a bona fide resident of Cumberland County, Pennsylvania, for
more than six months previously to the filing of this Complaint and continuing to the
commencement of this Action in Divorce.
4.
Plaintiffand Defendant were lawfully joined in marriage on December 1, 1956, in
Duncannon, Perry County, Pennsylvania.
-2-
WAYNE F. $~kDE
53 West Pomfret Street
Carlisle, Pennsylvania
17013
The parties have been living separate and apart since on or about April 11, 2002.
6.
Plaintiff avers as the grounds on which this action is based that the marriage of
the parties is irretrievably broken. In the altemative, Plaintiff avers as the grounds on
which this action is based that Defendant has offered such indignities to the person of the
Plaintiff, the innocent and injured spouse, as to render the condition of Plaintiff
intolerable and the life of Plaintiff burdensome. In the further alternative, Plaintiff avers
as the grounds on which this action is based that Defendant has committed willful and
malicious desertion, and absence from the habitation of the injured and innocent spouse,
without a reasonable cause, for the period of one or more years.
7.
There have been no prior actions for divorce or annulment of this marriage in
Pennsylvania or in any other jurisdiction.
8.
This Action in Divorce is not collusive.
9.
Both parties to this Action in Divorce are legally capable of managing their own
concerns.
-3-
10.
Defendant herein is not a member of the armed forces of the United States of
America.
11.
There were no children bom to this marriage.
12.
Plaintiffhas been advised that counseling is available and that Plaintiffmay have
the right to request that the Court require the parties to participate in counseling.
WHEREFORE, Plaintiff demands judgment dissolving the marriage between the
parties.
Wayne K Shade, Esquire
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
WAYNE F. SHADE
Attorney at Law
53 West Pomftet Street
Carlisle, Pennsylvania
17013
-4-
I verify that the statements made in this pleading are tree and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating
to unswom falsification to authorities.
Date: July 16, 2003
Martha F. Keifcr
WAYNE F. SHADE
'HA F. KEIFER,
Plaintiff,
VS.
LLIAM B. KEIFER, JR.,
Defendant
In The Court of Common Pleas
Of Cumberland County, PA
No. 03-3391 Civil Term
In Divorce,
ENTRY OF APPEARANCE
Please enter my appearance on behalf of 'the Defendant, William B.
Keifer, Jr., in the above- captioned matter.
Respectfully Submitted,
Andy J'. Watson,
Attorney for Defendant
1 E. Third Street
Coudersport, PA 16915
(814) 274-8612
Date: ~'/?,2003
-1-
L^w Omcr~s OF
LEBER & WATSON
ONE EAST THIRD ST.
COUDERSPORT, ]PA
MARTHA F. KEIFER,
Plaintiff,
V$,
WILLIAM B. KEIFER, JR.,
Defendant
In The Court of Common Pleas
Of Cumberland County, PA
No. 03-3391 Civil Term
In Divorce
AND NOW COMES Defendant, William B. Keifer, by and through his
attorney, Andy J. Watson, and respectfully files an Answer and Counted'claim
to Plaintiff's Divorce Complaint as follows:
ANS~VER
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted.
6. Denied. It is specifically denied that the marriage of the parties
is irretrievably broken as Defendant wishes to reconcile. It is further
specifically denied that Defendant has offered indignities, which has rendered
Plaintiff's condition intolerable and life burdensome, or that Plaintiff iS an
innocent and injured spouse. It is further specifically denied that Defendant
has committed willful and malicious desertion.
-1-
L^w Omcr~s OF
Lzaeg & W~,wsos
ONE Emu-'I~m~) ST.
COUDERSPOR'r, PA
7. Admitted.
8. Admitted.
9. Admitted.
10. Admitted.
11. Admitted.
12. No response required.
WHEREFORE, Defendant respectfully requests this Honorable ~Court
deny Plaintiffs demand for dissolution of the marriage.
COUNTERCLAIM
COUNT I - EQUITABLE DISTRIBUTION
OF MARITAL PROPERTY
13. The previous averments are incorporated herein by refeCence
and made a part hereof.
14. That during the course of their marriage, the parties hereto !have
acquired certain real and personal propertywhich is marital property under the
Divorce Code.
WHEREFORE, Plaintiff respectfully requests this Honorable CoUrt to
enter an Order equitably distributing the marital property.
-2-
COUNT II: SPOUSAL SUPPORT, ALIMONY PENDENTE LITE
AND PERMANENT ALIMONY
15. The previous averments are incorporated herein by reference
~nd made a part hereof.
16. That Plaintiff requires a reasonable amount of spousal Sal~port,
alimony pendente lite, and/or permanent alimony to meet his reasonabie and
necessary financial needs.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to
enter an Order awarding him spousal support, alimony pendente lite and/or
alimony.
COUNT III: ATFORNEY'S FEES, COSTS AND EXPENSES
LAW OFRCF~S OF
L~B]~R & WA'rsoN
ON£ E~r'l~mD
COUDF. P.S~ORr, PA
17. The previous averments are incorporated herein by reference
and made a part hereof.
18. That Plaintiff lacks the necessary income and resoumes to pay
his reasonable attorney's fees, costs, and expenses.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to
enter an Order granting Plaintiff reasonable attorney's fees, costs and
expenses.
-3-
LAW OFFICES OF
Le~ER & W,~XSO~
ONE EASX'r~Rt~ ST
COUDERSPO~T, PA
Date:
,2003
And'y-o'. V~atson, Attorney for Defendant
One East Third Street
P.O. Box 310
Coudersport, PA 16915
(814) 274-8612
-4-
L^w O~'~cy~s O~
L~ & W~,~so~
ONE E^ST T~D ST.
COUDERSPO~, PA
MARTHA F. KEIFER,
Plaintiff,
VS.
WILLIAM B. KEIFER, JR.,
Defendant
In The Court of Common Pleas
Of Cumberland County, PA
No. 03-3391 Civil Term
In Divorce
VERIFICATION
I verify that the statements made in the attached and foregoing Answer
and Counterclaim are true and correct. I understand that false staterinents
herein are made subject to the penalties of 18 Pa.C,$. §4904 relatilng to
unsworn falsification to authorities.
William B. Keifer, Defendant
Date:
LAW OFFICE5 OF
L~ & Wx~soN
ONE EAST THIRD ST.
COUDERSPORT, PA
MARTHA F. KEIFER,
Plaintiff,
VS.
WILLIAM B. KEIFER,
Defendant
In The Court of Common Pleas
Of Cumberland County, PA
No. 03-:3391 Civil Term
In Divorce
CERTIFICATE OF SERVICE
I, ANDY J. WATSON, Esquire, do hereby certify that two original
copies of the foregoing Interrogatories were served upon attorney for
Plaintiff, Wayne F. Shade,533 West Pomfret Street, Carlisle, PA 17013, by
First Class mail, this / o~ day of August, 2003.
AN D'Y~.,WATSON, Attorney for Defendant
1 East Third :Street
Coudersport, PA 16915
(814) 274-8612
-16-
MARTHA F. KEIFER,
Plaintiff,
VS.
WILLIAM B. KEIFER,
Defendant
In The Court of Common Pleas
Of Cumberland County, PA
No. 03-.3391 Civil Term
In Divorce
INTERROGATORIES PURSUANT TO
Pa.R.C.P. 1930.5
The Defendant, William B. Keifer, by and through his attorney, Andy
J. Watson, does hereby propound the following Interrogatories upon the
Plaintiff, Martha F. Keifer, to be answered under oath, within thirty (30) days
after the receipt hereof as required by PaRCP No. 4005 and 4006.
These Interrogatories shall be deemed to be continuing and any
information or documents secured subsequent to the filing of Answers
thereto, which would have been included in the Answers had it been known
or available, shall be supplied by Supplemental Answers as soon as such
information becomes known or available, but in all events prior to the trial of
this action, pursuant to PaRCP No. 4007.4.
Each Interrogatory hereinafter set fo~h, not only calls for your
knowledge but also for all information that is available to you by reasonable
inquiry, including inquiry of your representatives and attorneys.
-1-
.LAw O~cr~ O~
L~ & WA~O~
COUDER~PORT, PA
These Interrogatories shall be deemed to be continuing
Interrogatories. If, between the time of your Answem and the time of tdal of
this case, you or anyone acting in your behalf, learn of any further
information not contained in your Answers, any such additional information
shall be promptly furnished to the undersigned by supplemental answers.
ANSWERS AND DEFINITIONS
Answer every Interrogatory. No question is to be left blank. If the
answer to an Interrogatory is "none" or "unknown", such statement must be
written in the answer. If the question is inapplicable, "n/a" must be written in
the answer.
Whenever a date, amount or other computation or figure is requested,
the exact date, amount, computation or figure is to be given unless it is
unknown. If so, give the best estimate or approximation.
Whenever the word "identify" or "identity" is used in reference to a
person, corporation, or other entity, this means to state his, her, or its full
name, present add~ess, home telephone number, and business affiliation
and business telephone number.
-2-
L~w O~:~c~s O~
L~ & WA~O~
Couo£P.S~owr, PA
INTERROGATORIES
1. State your:
a. Full Name
b. Date of birth
c. Residence
If you pay rent, state the monthly amount and to
whom paid.
d. Social Security Number
e. Date of this marriage
fo
Identify all persons with whom you currently reside on
a full time basis and their' monthly income.
2. State your complete educational background, including all post
high school education and training, whether or not any degree or certificate
was obtained.
3. For each of your present job(s) and present souirce(s) of
earned income, and for each job or source of earned income you have had
in the past two (2) years, state:
a. Your job title;
-3-
L~w Omens O~
L~s~ & WA~SO~
0~ E~r T~ra) ST
Cou~.~s~oa'r, PA
b. Your job duties;
C=
Your date of hire or starting and date of termination or
ending;
d. The reason(s) for termination or ending;
e. Your salary or eamings;
f:~~e b~t~[i.e:i p~i~n
insurance, retirement plans, etc.) and the amount
contributed each year to any retirement plan; and
go
Any and all jobs that you have been offered but
declined in the last ten (10) years.
If you are self-employed, please provide a detailed list
of any and all tools, equipment, and business assets
and the value of each item.
If self-employed, please attach copies of businesses'
books showing your income, labor, materials, net
income and provide your present net monthly income.
4. Please state any and all other sources of income, besides
income which you receive from employment, from any source.
5. State what date you contend is the date of final separation of
you and your spouse, and state each and every reason why you believe final
separation occurred on that date.
-4-
6. For each automobile or other vehicle of any nature whatSoever
owned by you or your spouse, or in which you had or have an interest, either
at present and at the date of final separation, state:
a. The make, model and year of manufacture;
b. The date acquired;
Co
The purchase price (or, if not purchased, the value at
time of acquisition);
d. The source of the purchase funds;
e=
Identify any co-owners and any lienholder and the
amount of the lien; and
f. The fair market value of the vehicle.
7. For each household item, furniture, jewelry, furs, antiques, art
work collections or any other item of personal property with a value
exceeding $100.00, state:
a. A description of the item;
b. The date the item was acquired;
The purchase price (or, if not purchased, the value at
time of acquisition);
The fair market value of the item at the date of
separation and at present;
LAw OFFIC~ OF
L~zz & W~,~o~
ONE EAST THIRD ST.
COUD£RSPORT, PA
-5-
e. Identify the person in possession of the item; and
If not purchased by you or your spouse, how the item
was acquired.
8. Identify any and all madtal property currently in your
possession and its value.
9. lcFen/ifyanyand all r~adtal property currentlyin your sl3Touse's
possession and its value.
10. Identify all bank, savings and loan associations and similar
accounts, time deposits, certificates of deposit, savings bonds, treasury
notes, treasury bills, savings clubs, thdft plans, money market funds,
annuities (tax sheltered or otherwise), savings accounts or checking
accounts in your name or in which you have any interest. For each item,
state:
a. The nature of the item;
b. The location of the item;
c. The account number or other identifying information;
The balance therein or value thereof as of the date of
separation and at the present;
e. Identify any co-owner;
.L^w O ~'~oas OF
LEBEZ & WATSON
OHE E~I' THIRD ST.
COUD£P. SPOm', PA
-6-
fo
Identify the custodian of the passbook or other means
of authorization, if any; anti
go
The source of the monies which purchased the item or
which were deposited in the account.
11. Identify any safe deposit boxes, vaults, safes or othe[ places
of deposit and safe keeping in which you deposited money, documents, or
other items of property during your marriage. For each item, state:.
a. The ham~ and location Of the institUtion wWer~ it is
located;
b. 'The name or names in which it is registered;
c. The number or other identifying informatiOn;
d. itemize the contents and value thereof;
e. Identify all who have access thereto; and
The number of times it was visited in the last three
years and the purpose of each visit.
12. Identify all shares of stock, securities, bonds, and any other
investments (excluding real estate) which you~ own or in which youi have an
ownership interest. For each item, state:
A description of the nature of the item, including the
number of shares owned at separation and the number
of shares owned presently;
Ce
fo
go
ko
Identify any co-owners or interest holders other than
yourself;
The date(s) of acquisition;
The purchase pdce;
If not purchased, the value at acquisition;
The value per share on the date of separation, and the
present value per share;
Its present location;
The amount and frequency of any dividends, interest or
income payable;
The maturity date of any {bond;
Whether any item is subject to any lien or security
interest and, if so, identify the holder of the lien or
security interest, the amount thereof, and the reason
for the lien or security interest; and
Identify the custodian of any certificate or other written
· evidence of such investment.
Whether you have invaded the principal or cashed out
any said investments within the past two (2) years, and
the date and value thereof when cashed.
-8-
· L~w O~s O~
L~u~g & W~TSON
CO{JDERSPORT, PA
13. For each parcel of real estate in which you hold title or any
ownership interest, state:
a. The location (mailing address and municipality);
b. A description of the property and any improvements,
including deed book and page number;
c. The nature of your ownership interest;
d. The date acquired;
e. The purchase price;
f. If not purchased, its value at acquisition and the manner
by which you acquired ownership;
g. The fair market value at the date of separation and at
present;
h. Identify any co-owner and their interest;
I. Identify any mortgage holder or lien holder andlthe date
and present amount of ally lien and the amount of any
lien on the date of final separation; and
j. If you have received any rents or income from or for the
use of the property at any time in the last two {2) years,
state the amount of rent or income recei[ved, the
frequency of receipt, and the identity of the payer(s).
-9-
.LAw OFFIOES OF
LEaea & W~.m'so,
Or~£ EASt TmRv ST
COUrt. SPORt. PA
14. Are there any outstanding obligations, including but not limited
to mortgages, contract obligations, promissory notes, credit cards, and/or
other marital debt or liabilities executed by you, or by you jointly with any
other person? If so, for each such obligation, state:
a. Identify the creditor;
b. The nature of the obligation;
c. The account or loan number;
d. The date the obligation was incurred;
e. What benefit you received for assuming liability for the
obligation (such as monies loaned to you or other
benefits which you may have received);
f. The amount and frequency of any payments thereon;
g. The unpaid balance of the obligation at the date of
separation and at present; and
h. A description of any property given to secure repayment
of the obligation.
15. Within the past one (1) years, have you bought, sold or
transferred any item of property of any nature having a value in excess of
$500.00? If so, for each such sale or transfer, state:
Identify the property sold;
The date of the sale or transfer;
LAW OFFI~ OF
LE~ER & v~rATSON
Or~ E^s'r T.r~ ST.
COUDERSPO~T, P~
c. The sale pdce;
d. Identify any salesperson, agent or broker involved in the
sale;
e. Identify the purchaser;
f. The net gain or loss resulting from the sale;
g. The date you acquired properb/; and
h. Your purchase price for the property and the cost of any
improvements made to it (if not purchased, then state
the value at the time of acquisition).
16. Is any person or entity holding iQ trust for your benefit or use
any item of property? If so, for each such item:
a. Identify the custodian;
b. Identify the item of property held by the custodian; and
c. The fair market value of the item.
17. Are you a party to any contract or option of any kind, not
already identified in any other Answer?. If so, provide the details of such
contract or option and attach copies of all documents relating thereto.
18. Do you contribute to any person's support or welfare? If so, for
each such person, state:
-11-
L^w Omc~s O~
L~R & W~,xso~
O~E Essr'l~mr~ S~.
COU~£~S~O~T, PA
a. Identify the person;
b. The relationship of such person to you;
The amount and frequency of payments made by you
to that person;
d=
Whether payments are voluntary, by agreement Or court
order; and
If there is any court proceeding involved other than this
divorce, please give the proceeding by Court and
docket number.
19. Do you expect to inherit any Property or money in the ~uture,
and, if so, from whom and in what amount?
20. Are you the owner of, or do you have any ownership interest
in, or have you invaded the principal of, within the past two (2) years, any
IRA account, SEP IRA, 401(k), Keogh plan, defined contribution or defined
benefit pension plan, annuity, profit sharing plan or any other pension or
retirement Plan, asset or fund of any nature whatsoever?. If so, for each
item, state:
a. The nature of the item;
bo
Identify the holder of the assets or custodian:of the
plan;
Co
The amount or value of all contributions made by' you or
on your behalf (i.e., by your' employer) from the Uate of
marriage until the date of separation;
-12-
.L~w O~c~s O~
L~z~ & WA~sos
0~£ F~ ~l~mv Sr.
COUDF. RSPOKI', PA
The monthly benefits which you would or could receive
upon retirement at normal retirement age, based upon
contributions made from the date of marriage until the
date of separation;
The monthly benefits which you would or could receive
upon retirement at normal retirement age, based upon
all contributions made to the present;
f=
If not a pension plan, the balance in the I~lan or
account, both at present and on the date Of final
separation; and
If a pension, the present value of the plan, both at
present and on the date of final separation.
If the principal has been invaded or cashed in dudng
the last two (2) years, the gross amount received and
date thereof.
Whether you have ever rolled over retirement funds into
other investments or retirement plans, and, if so, the
amount rolled over, type of investment rolled over into,
and the current value of said investment.
21. Do you have any interest of any nature whatsoever in any
property not identified in any other Answer, whether you hold the @reperty
personally, you hold it for someone else, or it is being held for you? if so, for
each such item of property, state:
a. The nature of the preperty;
b. The nature of your interest;
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L^w Omc'Es OI,
LE~R & WA'rSON
ONE EAST T~IRD ST.
COUt)£RSPORT, PA
c. The location of the property;
d. The value of the property; and
e. Identify any co-owner or other person having any
interest in the property.
22. For each policy of life insurance that you own, are named as
beneficiary, or which insures your life, state:
a. Identify the insurer;
b. Identify the person whose life is insured;
c. The amount paid upon the death of the insured;
d. The nature of the policy (i.e., term, whole life, combined
life, etc.);
e. The cash surrender value of the policy at separation;
f. The date the policy was taken out;
g. Identify who pays the premium for the policy land the
amount of the annual premium; and
h. Identify any and all beneficiaries to such policies.
23. State the name, address and telephone number of ea(~h expert
witness that you expect to call at the trial of this case and, for each expert,
state:
.LAw OFF~C~ OF
LEBER ~C WATSON
ONE F~ST Ta~ ST.
COUD~O~, PA
A complete curriculum vitae, including but not limited to
all schools attended, the dates of attendance and
degrees received; any other education or training
received, whether professional or not, and setting forth
where and when received; entire employment history
which is directly or indirectly connected with her area of
expertise; and all experience or qualifications relevant
to her area of expertise;
b=
The subject matter upon Which the expert is expected
to testify;
The substance of the facts and opinions to which the
expert is expected to testify;
d. A summary of the grounds 'for each such opinion; and
Your Answers to b, c, and d above must be signed by
the expert, or you may attach a copy of the expert's
report to your Answers to these Interrogatories.
24. State your adjusted gross income for the past two (2) calendar
years, and attach a copy of your Federal Income Tax returns for thosel years
to your AnsWers.
25. List any and all marital or non-marital real or personal property
which you contend were received by gift or inheritance.
Date:
ANDY J. WAToON, Attomey for Defendant
1 East Third Street
Coudersport, PA 16915
(814) 274-8612
, 2003
WAYNE F. SHAD[
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
MARTHA F
Plaint
Vo
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Defer
WAY
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Date: Octot
KEIFER,
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.. KEIFER, JR.,
dant
: IN THE COURT OF COMMON PLEAS O]
: CUMBERLAND COUNTY, PENNSYLV^
: CIVIL ACTION - LAW
:
: NO. 03-3391 CIVIL TERM
:
: 1N DIVORCE
AFFIDAVIT OF SERVICE
NE F. SHADE, ESQUIRE, certifies that he is counsel for Plaintiff in tl~
ned matter, that he did, on July 16, 20,03, serve the Complaint in Divon
~tioned matte? upon Defendant by certified United States mail, postage
n receipt requested, addressee only, and that the same was received by
~ July 19, 2003, as evidenced by the return receipt card attached hereto
fied No. 7099 3400 0018 5044 8653. It is understood that false statem
~de subject to the penalties of 18 Pa.C.S. §4904 relating to unswom
to authorities.
er 28, 2003
Wayn~F. Shade
rots
.55
2.30
1.75
3.50
$ 8.10
Postmark
Here
July 16,
t, t.N 'orPOB o
gox
C::I q~, sram, z,/P+4
~ ~ustln PA 16720
2003
· 1, 2, and 3. Al~o ~
~m 4 if Re.Tiered Delivery Is dee~e~.
· F~ your n~e ~ ~ ~ ~e mv~
'~e ~ ~um ~ ~ to y~.
· A~ c~ to the ~ck of the mall~e,
or on the front if
1. Article Addressed to:
William ~B. Keifer,
P.O. Box 194
Austin, PA 16720
Jr.
PS Fo~m 3811, August 20el
D. Is daite~ addmae dlffere~ from item 1 ?
If YES, enter delivery addree~ below:
i-1 Agent
i"'l No
r'~certifled Mall D Expma~ Mail
[] Registered n Return Receipt for Merchandise
I ~1 [] Insured Mail [] C.O.D.
7099 3400 0018 5044 8653
O~ [~stum ~ 1~M~35
MARTHA F. KEIFER,
Plaintiff
WILLIAM B. KEIFER, JR.,
Defendant
: 1N THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
:
: NO. 03-3391 CIVIL TERM
:
: IN DIVORCE
AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE
OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER §3301 (c)
OF THE DIVORCE CODE
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF POTTER )
A Complaint in Divorce under §3301(c) of the Divorce Code with Notice of
Availability of Counseling was filed on July 16, 2003, and served on July 19, 2003.
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.
I consent to the entry of a Final Decree of Divorce without notice.
I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses ifI do not claim them before a divorce is granted.
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 of my right to
counseling and understand that I may request that the Court require that my spouse and I
participate in counseling.
7.
I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
8.
Being so advised, I do not request that the Court require that my spouse and I
participate in counseling prior to a Divorce Decree's being handed down by the Court.
9.
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 unswom falsification to authorities.
Date: January aa , 2004
William B. Keifer, Jr.
WAYNE F. SHADE
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT, madethis 8th dayof January ,2004, at
Carlisle, Cumberland County, Pennsylvania, by and between MARTHA F. KEIFER of
3804 Vine Street, Camp Hill, Pennsylvania 17011 (hereinafter referenced as "Wife")
AND
WILLIAM B. KEIFER, JR., of P.O. Box 194, Austin, Pennsylvania 16720 (hereinafter
referenced as "Husband").
ARTICLE I
SEPARATION
1.01 Separation of Parties. Differences have arisen between the parties as a
result of which they have been living separately and apart since April 11, 2002.
1.02 Intention to Live Apart. The parties intend to maintain separate and
permanent domiciles and to live apart from each other. It is the intention and purpose of
this Agreement to set forth the respective rights and duties of the parties while they
continue to live apart from each other and to settle all financial and property rights
between them.
ARTICLE II
ENFORCEABILITY AND CONSIDERATION
2.01 Equitable Distribution of Marital Property. The parties have attempted to
divide their marital property in accordance with the statutory rights of the parties and in a
manner which conforms to the criteria set forth in §401 of the Pennsylvania Divorce
WAYNE F. SHADE
Attorney at Law
Code, and taking into account the following considerations: Any prior marriages of the
parties; the age, health, station, amount and soumes of income, vocational skills,
employability, estate, liabilities and needs of each of the parties; the contributions of each
party; the opportunity of each party for future acquisition of capital assets and income;
the sources of income of each party, including, but not limited to, medical, retirement,
insurance or other benefits; the contribution or dissipation of each party in the
acquisition, preservation, depreciation or appreciation of marital property, including the
contribution of each party as homemaker; the value of the property set apart to each
party; the standard of living of the parties established during the marriage; and the
economic circumstances of each party at the time the division of property is to become
effective.
The division of existing marital property is not intended by the parties to constitute
in anyway a sale or exchange of assets, and the division is being effected without the
introduction of outside funds or other property not constituting marital property. The
division of property under this Agreement shall be in full satisfaction of all rights of
equitable distribution of the parties.
2.02 Incorporation and Merger. This Agreement shall be incorporated but not
merged in the decree of divorce contemplated herein. This Agreement shall survive any
action for divorce and decree of divorce and, unless otherwise set forth herein and shall
forever be binding and conclusive on the parties; and any independent action may be
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WAYNE F. SHADE
Attorney at Law
53 West Pomf~t Street
Carlisle, Pennsylvania
brought, either at law or in equity, to enforce the terms of this Agreement by either
Husband or Wife until it shall have been fully satisfied and performed. Any provisions
herein concerning property rights, alimony and counsel fees shall not be modifiable. The
considerations for this Agreement are the mutual benefits to be obtained by both of the
parties hereto and the covenants and agreements of each of the parties to the other. The
adequacy of the consideration for all agreements herein contained is stipulated, confessed
and admitted by the parties, and the parties intend to be legally bound hereby.
2.03 Agreement Predicated on Divorce. It is specifically understood and
agreed, by and between the parties hereto and each of the said parties does hereby
warrant and represent to the other, that the execution and delivery of this Agreement is
predicated upon an agreement for prosecution to conclusion of the pending action for
divorce. Nothing contained in this Agreement shall prevent or preclude either of the
parties hereto from commencing, instituting or prosecuting any action or actions for
divorce, either absolute or otherwise, upon just, legal and proper grounds; nor to prevent
either party from defending any such action which has been, may or shall be instituted by
the other party, nor from making any just or proper defense thereto. It is warranted,
covenanted and represented by Husband and Wife, each to the other, that this Agreement
is lawful and enforceable and this warranty, covenant and representation is made for the
specific purpose of inducing Husband and Wife to execute the Agreement. Husband and
Wife each knowingly and understandingly hereby waive any and all possible claims that
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WAYNE: F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle~ Pennsylvania
this Agreement is, for any reason, illegal or for any reason whatsoever of public policy,
unenforceable in whole or in part. Husband and Wife do each hereby warrant, covenant
and agree that, in any event, he and she are and shall forever be estopped from asserting
any illegality or unenforceability as to all or any part of this Agreement.
2.04 Representation by Independent Counsel. Each of the parties is represented
by independent counsel in the preparation and execution of this Agreement. Wife is
represented by Wayne F. Shade, Esquire, and Husband is represented by Andy J. Watson,
Esquire, ofLeber & Watson, LLP.
ARTICLE III
EQUITABLE DIVISION OF MARITAL PROPERTY
3.01 Equitable Division of Real Property.
(a) Concurrently with execution of this Agreement, Husband shall execute a
special warranty Deed to be prepared by counsel for Wife which will transfer to Wife all
of his right, title and interest in and to the real estate premises known and numbered as
3804 Vine Street, Camp Hill, Pennsylvania, and more particularly bonnded and described
in a Deed from J. Vincent McCarthy and Mary Ellen McCarthy to William B. Keller, Jr.
and Martha F. Keifer dated June 3, 1968, and recorded in Cumberland County Deed
Book "U", Volume 22, Page 402, with improvements thereon erected. The Deed shall be
held in escrow by counsel for Husband pending issuance of a full and final Decree in
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WAYNE F. SHADE
Divorce. Wife shall have exclusive possession of said real estate pending further
agreement of the parties or Order of Court.
(b) Concurrently with execution of this Agreement, Wife shall execute special
warranty deeds to be prepared by counsel for Husband which will transfer to Husband all
of her right, title and interest in and to the real estate premises more particularly bounded
and described in a Deed from Della Gertrude Johnston, et al., to William B. Keifer, Jr.
and Martha F. Keifer, dated January 26, 1972, and recorded in Potter County Deed Book
189, Page 12, with improvements thereon erected, and in a Deed from Edmond Rossetti
and Josephine Rossetti to William B. Keifer and Martha F. Keifer dated September 27,
1996, and recorded in Potter County Deed Book 261, Page 171. The deeds shall be held
in escrow by counsel for Wife pending issuance of a full and final Decree in Divorce.
Husband shall have exclusive possession of said real estate pending further agreement of
the parties or Order of Court.
3.02 Equitable Division of Personal Property.
(a) Concurrently with execution of this Agreement, Husband shall execute a
Limited Power of Attorney to be prepared by counsel for Wife which will transfer to
Wife all of his right, title and interest in and to the 2002 Lincoln Continental. The
Limited Power of Attorney shall be held in escrow by counsel for Husband pending
issuance of a full and final Decree in Divorce. Wife shall have exclusive possession of
said vehicle pending further agreement of the parties or Order of Court.
WAYNE F. SHADE
53 West Pomfrct Street
17013
(b) Concurrently with execution of this Agreement, Wife shall execute Limited
Powers of Attorney to be prepared by counsel for Husband which will transfer to
Husband all of her right, title and interest in and to a 1989 Suzuki 4-wheeler and a 1998
Ford F-150 pick-up truck. The Limited Powers of Attorney shall be held in escrow by
counsel for Wife pending issuance ora full and final Decree in Divorce. Husband shall
have exclusive possession of said vehicle pending further a~eement of the parties or
Order of Court.
(c) Husband shall retain absolute ownership of all firearms, with the exception of
a .22 caliber Ruger handgun, serial #6341364, which shall be the property of Wife.
(d) Husband shall retain absolute ownership of all antique clocks, approximately
54 in number, with the exception ora Seth Thomas railroad clock in the dining room of
the marital dwelling and a Seth Thomas red mantle clock that was a gift to Wife from her
mother, both of which shall be the property of Wife. Any property assigned to Husband
under the terms of this Agreement that is in the marital dwelling at 3804 Vine Street,
Camp Hill, Peunsylva~ia, and is not removed therefrom by Husband by 5:00 P. M. on
June 30, 200~[, shall be regarded as abandoned to Wife.
other similar untitled personal property that is in his possession in Potter County,
Pennsylvania.
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WAYNE F. SHADE
Attorney ~t Law
Carlisle, Pennsylvania
(f) Wife shall retain absolute ownership of all furniture, household goods and
other similar untitled personal property that is in her possession in Cumberland County,
Pennsylvania, other than the aforesaid firearms and clocks.
(g) Wife shall retain absolute ownership of the M&T Bank checking account
#505143775372, her Federal Civil Service Retirement System Thrift Savings Plan
account # 175301183, her Phoenix Investment Partners, Ltd. IRA, her MetLife life
insurance policy, five $200 U. S. Savings Bonds, Series EE, her New Cumberland
Federal Credit Union account #002001 and the right to one of the caskets, vaults and
interments in cemetery lots at Woodlawn Memorial Gardens, 4855 Londonderry Road,
Harrisburg, Pennsylvania.
(h) Husband shall retain absolute ownership of the Citizens Trust Company
savings account, the MetLife variable annuity #073318116AB, his ING Reliastar annuity,
his MetLife life insurance policy and the fight to one of the caskets, vaults and interments
in cemetery lots at Woodlawn Memorial Gardens, 4855 Londonderry Road, Harrisburg,
Pennsylvania.
(i) To complete equitable distribution, Wife will pay to Husband the sum of Forty
Thousand and NWl 00 ($40,000.00) Dollars immediately upon closing upon Wife's
financing for the same.
0) The parties will execute and deliver any documents necessary to formally
release their rights in or claims to the employee benefits, including without limitation,
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WAYNE F. SHADE
employee pension, stock, profit sharing and savings plans, if any, of the other. Such
release will expressly extend to all rights to pre-retirement death benefits and survivor
benefits and includes the unequivocal consent to the designation by the other of any
alternate or further beneficiaries at anytime. The parties acknowledge that the effect of
this release is that he or she will not be entitled to any benefits whatsoever from the
aforesaid employee benefits of the other.
(k) The parties will execute and deliver any documents necessary to formally
release their rights and all claims to the life insurance of the other.
ARTICLE IV
DEBTS OF PARTIES
4.01 Loans. Wife shall assume responsibility for payment of loan #JJA4808638
at Ford Motor Credit Company.
4.02 Post-Separation Obligations. Each party represents to the other that, except
as specifically set forth immediately above, there are no outstanding joint obligations of
the parties and that since the separation neither party has contracted for any debts for
which the other will be responsible.
4.03 Indemnification. Each party indemnifies and holds harmless the other for
all obligations separately incurred and for all obligations assumed under the provisions of
this A~'eement.
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WAYNE F, SHADE
ARTICLE V
ALIMONY
5.01 Waiver. Each of the parties waives alimony generally.
ARTICLE VI
COUNSEL FEES
6.01 Present Fees. In the event of amicable settlement of all marital issues and
the entry of a Decree in Divorce pursuant to mutual consent, each of the parties hereby
assumes his and her own counsel fees up to and including the date of the Decree in
Divorce.
6.02 Counsel Fees After Divorce. The parties agree with respect to counsel fees
incurred after the divorce, as follows:
(a) In the event that future legal proceedings of any nature may be necessary for
the interpretation or enlbrcement of this Agreement or any valid modifications hereof, the
substantially prevailing party shall be entitled to reasonable counsel fees incurred.
(b) Reasonable counsel fees hereunder shall be defined as reasonable hours
expended at the then hourly rate of counsel for the substantially prevailing party.
(c) Such counsel fees shall extend to any independent proceedings necessary to
collect counsel fees or to enforce any other judgment or decree in connection with this
Agreement.
WAYNE F. SHADE
(d) Such counsel fees shall be payable as alimony so as to constitute an exception
to discharge in bankruptcy but shall not be deductible by the payor or taxable to the payee
for income tax purposes.
ARTICLE VII
GENERAL PROVISIONS
7.01 Income Tax Consequences. The parties have heretofore filed joint federal
and state income tax returns. Both parties agree that in the event any deficiency in
federal, state or local income tax is proposed, or any assessment of any such tax is made
against either of them, each will indemnify and hold harmless the other from and against
any loss or liability for any such tax deficiency or assessment and any interest, penalty
and expense incurred in connection therewith. Such tax, interest, penalty or expense
shall be paid solely and entirely by the individual who is finally determined to be
responsible for the deficiency or assessment. Except as otherwise set forth herein, any
income tax incidents of any kind imposed by virtue of any transfers of assets or other
payments required under this Agreement will be the responsibility of the transferee.
7.02 General Release of Ail Claims. Each party hereto releases the other from
all claims, liabilities, debts, obligations, actions and causes of action of every kind that
have been incurred relating to or arising from the marriage between the parties.
However, neither party is relieved or discharged from any obligation under this
Agreement or any other instrument or document executed pursuant to this Agreement,
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WAYNE F. SHADE
Aitorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
7.03 Subsequent Divorce. Nothing herein contained will be deemed to prevent
either of the parties from maintaining a suit for absolute divorce against the other in any
jurisdiction based upon any past or future conduct of the other, nor to bar the other from
defending any such suit. In the event any such action is instituted or concluded, the
parties will be bound by all of the terms of this Agreement.
7.04 Waiver of Estate Claim. Except as otherwise herein provided, in the event
of the death of either party hereto, each party hereby waives, releases and relinquishes
any and all rights that he or she may have or may hereafter acquire as the other parties'
spouse under the present or future laws of any jurisdiction, as follows:
(a) to elect to take against the will or codicils of the other party now or hereafter
enforced.
(b) to share in the other parties' estate in cases ofintestacy.
(c) to act as executor or administrator of the other parties' estate.
7.05 No Debts and Indemnification. Each party represents and warrants to the
other that he or she will not incur any debt, obligation or other liability, other than those
already described in this Agreement, on which the other party is or may be liable. Each
party covenants and agrees that if any claim, action or proceeding is hereafter initiated
seeking to hold the other party liable for any other debt, obligation, liability, act or
omission of such party or for any obligation assumed by a party hereunder, the party
liable will, at his or her sole expense, defend the other against any claim or demand,
whether or not well-founded, and that he or she will indemnify and hold harmless the
other party in respect to all damages resulting therefrom. The obligation created
hereunder will be payable as alimony so as to constitute an exception to discharge in
bankruptcy.
7.06 Full Disclosure. Each party asserts that he or she has made a full and
complete disclosure of all of the real and personal property of whatsoever nature and
wheresoever located belonging in anyway to each of them, of all sources and amounts of
income received or receivable by each party, and of every other fact relating in anyway to
the subject matter of this Agreement. These disclosures are part of the considerations
made by each party for entering into this Agreement. The parties confirm that they have
relied on the completeness and substantial accuracy of the financial disclosure of the
other as an inducement to the execution of this Agreement. The parties acknowledge that
there has been no formal discovery issued to Husband in the pending divorce action and
that neither party has filed an inventory and appraisement as required by Section 3505(b)
of the Pennsylvania Divorce Code. Notwithstanding the foregoing, the rights of either
party to pursue a claim for equitable distribution, pursuant to the Pennsylvania Divorce
Code, of any interest owned by the other party in an asset of any nature at any time prior
to the date of execution of this Agreement that was not disclosed to the other party or his
or her counsel prior to the date of the within Agreement are expressly preserved. In the
event that either party, at any time hereafter, should discover such an undisclosed asset,
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WAYNE F. SHADE
the party shall have the right to petition the Court of Common Pleas of Cumberland
County to make equitable distribution of said asset. The party to whom the asset was not
disclosed shall be entitled to seek, from the non-disclosing party, payment of reasonable
counsel fees, costs or expenses incurred in seeking equitable distribution of said asset.
Notwithstanding the foregoing, this Agreement shall in all other respects remain in full
force and effect.
7.07 Right to Live Separately and Free from Interference. Each party will live
separately and apart from the other at any place or places that he or she may select.
Neither party will molest, harass, annoy, injure, threaten or interfere with the other party
in any manner whatsoever. Each party may carry on and engage in any employment,
profession, business or other activity as he or she may deem advisable for his or her sole
use and benefit. Neither party will interfere with the use, ownership, enjoyment or
disposition of any property now owned or hereafter acquired by the other.
7.08 Agreement Voluntary and Clearly Understood. Each party to this
Agreement acla~owledges and declares that he or she, respectively:
(a) Is fully and completely informed as to the facts relating to the subject matter of
this Agreement and as 1o the rights and liabilities of both parties.
(b) Enters into this Agreement voluntarily after receiving the advice of
independent counsel or. having had the opportunity to do so, having decided not to do so.
(c) Has given careful and mature thought to the making of this Agreement.
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(d) Has carefully read each provision of this Agreement.
(e) Fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
7.09 Compliance. The parties will execute and deliver any documents necessary
to formally conclude any of their obligations under the terms of this Agreement to each
other. Any failure of a party to execute and return to the other, within thirty (30) days of
receipt, a document that is necessary to formally conclude any obligation under the terms
of this Agreement shall be regarded as a material breach of this Agreement.
7.10 Default. If either party fails in the due performance of any of his or her
material obligations hereunder, the party not in default will have the right to act against
the other, at his or her election, to sue for damages for breach hereof, or to rescind this
Agreement or seek such other legal remedies as may be available to either party. Nothing
herein shall be construed to restrict or impair either party in the exercise of this election.
The failure of either party to insist upon strict performance of any of the provisions of
this Agreement shall not be construed as a waiver of any provision of this Agreement or
of the right to require strict performance of any other obligations under this Agreement.
7.11 Amendment or Modification. This Agreement may be amended or
modified only by a written instrument signed by both parties.
WAYNE F. SHADE
Ai~omey at Law
53 West Pomfrel Street
Carlisle, Pennsylvania
17013
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7.12 Successors and Assigns. This Agreement will be binding on and inure to
thc benefit of the respective legatees, devisees, heirs, executors, administrators, assigns
and successors in interest of the parties.
7.13 Law Governing Agreement. This Agreement shall be governed by and
construed in accordance with the laws of the Commonwealth of Pennsylvania in effect at
the date of execution hereof irrespective where in the world either or both of the parties
hereto may reside, be domiciled or own property in the future.
7.14 Condition Subsequent. This Agreement is expressly contingent upon the
parties' filing mutual consent to the pending divorce proceedings within thirty (30) days
of the date of this Agreement, which consent will not be revoked prior to issuance ora
full and final Decree in Divorce. In the event of failure or revocation of consent as
required herein, this Agreement shall become null and void. This Agreement is further
expressly contingent upon Wife's ability to borrow thc sum of Forty Thousand and
No/100 ($40,000.00) Dollars at prevailing market interest rates for residential first
mortgages.
7.15 Reconciliation. Irrespective of the reference in the title of this Agreement to
marital separation, this Agreement is intended to be a postnuptial agreement. In thc event
of reconciliation, attempted reconciliation or other cohabitation of the parties hereto of
short or long duration after the date of this Agreement, this Agreement shall remain in full
WAY,NE F. SHADE
Attorney at Law
53 w¢~teo~t~t st~t force and effect in the absence of a written Agreement signed by both parties hereto
Carlisle, Pennsylvania
expressly setting forth that this Agreement has been revoked or modified. Any attempted
reconciliation which does not result in a written agreement signed by both parties hereto
expressly setting forth that this Agreement has been revoked or modified shall not
establish any additional marital rights or obligations as a result of the attempted
reconciliation.
1N WITNESS WHEREOF, the parties hereto have hereunto set their hands and
Martha F. Keifer
seals, intending to be legally bound hereby, the day and year first above written.
Signed, Sealed and Delivered
in the Presence of:
(SEAL)
William B. Keifer, Jr.
WA Y~E F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
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STATE OF FLORIDA
COUNTY OF MONROE
On this, the ~ ~'Jh day of
)
) SS:
)
,2004, before me, the
undersigned officer, personally appeared MARTHA F. KEIFER, known to me (or
satisfactorily proven) to be the person whose name is subscribed to the foregoing
Agreement and acknowledged that she executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
~.~ ~, Rob~'l M Sch~tt~'
!'~. ~co~mi.i~ ooo~o.~ Notary Public
WAYNE F. SHADE
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COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF POTTER )
On this, the ~u day of ~AqyV~
,2004, before me, the
undersigned officer, personally appeared WILLIAM B. KEIFER, JR., known to me (or
satisfactorily proven) to be the person whose name is subscribed to the foregoing
Agreement and acknowledged that he executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Notary Public
Notarial Seal
Dent~e M. Miller, Notary Poblic
amy comnussio~ F. xpit~ 11~. 19, 21105
WAYNE F. SHADE
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WAYNE F. SHADE
MARTHA F. KEIFER,
Plaintiff
WILLIAM B. KEIFER, JR.,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-3391 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
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 3301(c) of the Divorce
Code.
2. The date and manner of service of the Complaint were July 16, 2003, by United
States certified mail, postage prepaid, addressee only.
3. Date of execution of the Affidavit of Consent and Waiver of Notice of
Intention to Request Entry of a Divorce Decree under §3301(c) of the Divorce Code by
Plaintiff was January 24, 2004, and by Defendant was January 8, 2004.
4. Related claims pending: None.
Date: February 13, 2004
WayneeF. Shade
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
STATE OF
MARTHA F. KEIFER,
Plaintiff
OFCUMBERLANDCOUNTY
PENNA.
NO. 03-3391 CIVIL TERM
VERSUS
Defendant
JR. ~
DECREE IN
DIVORCE
AND NOW,
DECREED THAT
~'~/.~,,~.~, /~'a , '2'~O/~/, IT IS ORDERED AND
MART}LA F. KEIFER , PLAINTIFF,
AND
WILLIAM B. KEIFER, JR. , 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;
All other claims have been resolved in a Property Settlement
aL~d Separation Agreement dated January 8, 2004, a copy of which
is attached and incorporated, but not merged, herein by
reference as though fully set fnrtb.
BY THE COURT: . /
PROTHONOTARY