HomeMy WebLinkAbout99-07019?si:
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IN THE COURT OF COMMON FLEAS
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OF CUMBERLAND COUNTY
STATE OF
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DEBRA _J....KG ......
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Plaintiff Nct..99CIVIL TERM °.•,
ti Vcr,us
.. SANDY,,.A,,..KECK
..Defendant. .,
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DECREE IN
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DIVORCE
AND NOW, ......:??n (... • ..ly ... , . 1-4 v... , , it is ordered and
Debra J Keck
decreed that .................................................. plaintiff,
and .....sandy ....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; o
The. partias . inaorpoxate,..but. .do . not merge,..their..PrQpertY,
settlement and .Separation.Agreement dated March 21, 2000. ,,, •, ':;
By T e o
Co rt v
• Attes J. ?c
Prothonotary
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PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT, made this day of ?7U Lc,4 , 2000, at
Carlisle, Cumberland County, Pennsylvania, by and between SANDY A. KECK of 405
High Mountain Road, Shippensburg, Cumberland County, Pennsylvania 17257
(hereinafter referenced as "Husband")
AND
DEBRA J. KECK of Walnut Bottom, Cumberland County, Pennsylvania (hereinafter
referenced as "Wife").
ARTICLE I
SEPARATION
1.01 Separation of Parties. Differences have arisen between the parties as a
result of which Husband and Wife have decided to separate themselves from marital
cohabitation since on or about September 15, 1999.
1.02 Intention to Live Apart. Husband and Wife desire to end the marriage'and
agree to termination of the marriage. 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
WAYNE F. SHADE
AMmeyw law
53 West Pom9a S"
culisle, Peauyl uix
17013
divide their marital property in accordance with the statutory rights of the parties and in a
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manner which conforms to the criteria set forth in §401 of the Pennsylvania Divorce
Code, and taking into account the following considerations: Any prior marriages of the
'parties; the age, health, station, amount and sources 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
WAYNE F. SHADE
Mtomry a law
53 Wat Pomfret Street
culisle, Pcnmyly is
17013
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, except
as to issues of child support and child custody, shall forever be binding and conclusive on
the parties; and any independent action may be brought, either at law or in equity, to
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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
counsel fees shall not be modifiable except as expressly stated in paragraph 8.11 of
this Agreement. 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
on an agreement for prosecution to conclusion of the pending action for divorce.
II Nothing contained in this Agreement shall prevent or preclude either of the parties hereto
II 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
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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
WAYNE F. SHADE
Adam yst law each knowingly and understandingly hereby waive any and all possible claims that this
33 wm Pomrrt suet
Carlisle. Pennsylvania
17013 11
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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 hereto are
represented by their own independently selected private counsel: Husband by Wayne F.
Shade, Esquire, and Wife by Dirk E. Berry, Esquire.
ARTICLE III
EQUITABLE DIVISION OF MARITAL PROPERTY
3.01 Equitable Division of Real Property. Upon execution of this Agreement
by Wife, she shall place into escrow with her counsel an executed and acknowledged
Deed transferring her interest in the marital real estate to Husband. The Deed will be
prepared by counsel for Wife at the expense of Wife and will be held in escrow pending
issuance of a full and final decree divorcing the parties from the bonds of matrimony and
pending the payment by Husband to Wife of the sum of Thirty Thousand and No/100
($30,000) Dollars which payment will be due within ten (10) days of issuance of the
Decree in Divorce. This entire Agreement shall be contingent upon Husband's being able
to borrow the sum of Sixty Thousand and No/100 ($60,000) Dollars at prevailing
residential mortgage interest rates.
3.02 Equitable Division of Personal Property.
WAYNE F. SHADE
Attorney at IAw
53 Wcst Pomfret SUcct
Culisle, Pennsy1mia
17013
(a) Wife shall be entitled to a hunting bow and to a bowling ball which are in the
marital residence. All motor vehicles and all furniture, household goods and other similar
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untitled personal property have been divided to the mutual satisfaction of the parties
hereto, and each of the parties retains absolute ownership of such items in his or her
or control at the date of this Agreement. The property shall be deemed to be
in the possession or under the control of either party if, in the case of tangible personal
property, the item is physically in the possession or control of the party at the time of the
signing of this Agreement and, in the case of intangible personal property, if any physical
or written evidence of ownership, such as passbook, checkbook, policy or certificate of
insurance or other similar writing is in the possession or control of the party, unless
provided otherwise in this Agreement.
(b) The parties will execute and deliver any documents necessary to formally
release their rights in or claims to the employee benefits, including without limitation,
employee pension, stock, profit sharing and savings plans, if any, of the other; and .
(c) 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. Husband shall see to the full payment and satisfaction of the existing
WAYNE F. SHADE
Attorney at IAw
53 West Pom0ar 5ueet
Carlisle. Penmy1 +is
1701]
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mortgage in the process of refinancing the marital dwelling. He shall also be responsible
for payment of his truck lease and the Visa, Sears and J. C. Penny revolving credit
)bligations to which he is a party.
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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. Each party indemnifies and holds harmless the other
for all obligations separately incurred or assumed under this Article IV.
ARTICLE V
CHILDREN
5.01 Custody. The parties shall have shared legal custody of their son, Jeremiah
Shane Keck, born December 14,1982, as contemplated by 23 Pa.C.S. §5302. Primary
physical custody of said child shall be in Husband subject to reasonable rights of partial
physical custody in Wife as the parties hereto may from time to time agree.
5.02 Support. Child support shall be resolved outside the terms of this
Agreement.
ARTICLE VI
ALIMONY
6.01 Waiver. Each of the parties waives alimony generally.
ARTICLE VII
COUNSEL FEES
WAYNE F. SHADE
Attom y at law
53 west Pamfm smxt
eui(ile. Pennsy1mi.
17013
7.01 Present Fees. In the event of amicable settlement of all marital issues and
e entry of a Decree in Divorce pursuant to mutual consent within ninety (90) days from
e date of this Agreement, each of the parties hereby assumes his and her own counsel
fees up to and including the date of the Decree in Divorce.
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0.
7.02 Counsel Fees After Divorce.
incurred after the divorce, as follows:
The parties agree with respect to counsel fees
I' (a) In the event that future legal proceedings of any nature may be necessary for
the interpretation or enforcement of this Agreement or any valid modifications hereof, the
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 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.
(d) Such counsel fees shall be payable as an exception to discharge in bankruptcy
but shall not be deductible by the payor or taxable to the payee for income tax purposes.
ARTICLE VIII
GENERAL PROVISIONS
WAYNE F. SHADE
Attorney ?t law
33 Weu poMr"Street
c"USIe, Pemuyly is
17013
8.01 Income Tax Consequences. The parties have heretofore filed joint federal
and state income tax returns. For 1999, the parties will either file jointly or Husband will
lay any federal income tax due over and above Wife's withholdings if she files
eparately. Both parties agree that in the event any deficiency in federal, state or local
icome tax is proposed, or any assessment of any such tax is made against either of them,
ich will indemnify and hold harmless the other from and against any loss or liability for
ly such tax deficiency or assessment and any interest, penalty and expense incurred in
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connection therewith. Such tax, interest, penalty or expense•shall be paid solely and
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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;
8.02 General Release of All 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.
8.03 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.
1 8.04 Waiver of Estate Claim. Except as otherwise herein provided, in the event
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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;
WAYNE F. SHADE
Attomcy at law (b) to share in the other parties' estate in cases of intestacy; and
53 West Pomfrtt Strut
Carlisle, Pcnnsylmis
17013
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(c) to act as executor or administrator of the other parties' estate.
8.05 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 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 so as
to constitute an exception to discharge in bankruptcy.
8.06 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.
8.07 Right to Live Separately and Free from Interference. Each party will live
WAYNE F. SHADE
AOOtney at law
33 West Pomfra Shat
Whit. Pemuy1mia
17013
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,
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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.
8.08 Agreement Voluntary and Clearly Understood. Each party to this
Agreement acknowledges 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 to the rights and liabilities of both parties;
(b) Enters into this Agreement voluntarily after receiving the advice of
independent counsel;
(c) Has given careful and mature thought to the making of this Agreement;
(d) Has carefully read each provision of this Agreement; and
(e) Fully and completely understands each provision of this Agreement, both as to
the subject matter and legal effect.
8.09 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.
8.10 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 sue for
rescission of this Agreement or seek such other legal remedies as may be available to
WAYNE F. SHADE
Anorney at L4W
53 West Pomfsa Sum
calisle. Pennrytvenia
17013
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either party. Nothing herein shall be construed to restrict or impair either party in the
exercise of this election.
8.11 Amendment or Modification. This Agreement maybe amended or
modified only by a written instrument signed by both parties.
8.12 Successors and Assigns. In the event of the death of either party prior to
the issuance of a Decree in Divorce, this Agreement shall survive the death; and all
property, whether jointly or separately owned, shall be divided under the terms of this
Agreement between the estate of the decedent and the surviving spouse as though the
Decree had issued prior to the death. Except as otherwise expressly provided herein, this
Agreement will be binding on and inure to the benefit of the respective legatees, devisees,
heirs, executors, administrators, assigns and successors in interest of the parties.
8.13 Law Governing Agreement. This Agreement will be governed by and will
be construed in accordance with the laws of the Commonwealth of Pennsylvania in:effect
at the date of execution hereof.
8.14 Reconciliation. In the event of reconciliation, attempted reconciliation or
other cohabitation of the parties hereto after the date of this Agreement, this Agreement
shall remain in full force and effect in the absence of a written Agreement signed by both
parties hereto expressly setting forth that this Agreement has been revoked or modified.
WAYNE F. SHADE
Alton" at LAW
53 Wat Pomfret Snes
culisle, Pennsylvania
17013
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IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and
WAYNE F. SHADE
Atmrney at law
53 West Pomfret Strta
culislc. Pcnnsylr is
17013
seals, intending to be legally bound hereby, the day and year first above Written.
'Signed, Sealed and Delivered
in the Presence of:
LLUJ (SEAL)
Debra J. Keck
Q /yf? (SEAL)
Sandy A. It?cj
_12_
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS:
On this, the o Z41• day of 2000, before me, the
undersigned officer, personally appeared SANDY A. KECK, 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 P lic
Connie J. Trill Notary Public
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF CUMBERLAND )
On this, the ISM day of MR rC h , 2000, before me, the
undersigned officer, personally appeared DEBRA J. KECK, 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.
WAYNE F. SHADE
Anomey at raw
57 West P mfmt Street
wisle. Pennsylvania
17017
n d >f' ??, or??nl
Loh
Notary Public
NOTARIAL UAL
MICHELE E. SyxoCk Na!ay.P?:bak
CorEtb Bute, 1067 arlarrd Car ry
MY n ExPim Juno 16, :003
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Notarial Seal
Carlisle. Cumberland County
My Commission ExpiresOct. S, 2000
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IN THE COURT OF COMMON PLEAS
DEBRA J. NECK,
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. CIVIL DIVISION
SANDY A. NECK, CIVIL TERM
Defendant NO. 99-7019
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce decree:
Ground for divorce:
Irretrievable breakdown under §3301(c)
??c?;?(?(l0]Ak#at?22t4r?f?ic?iaX
(Strike out inapplicable section).
2. Date and manner of service of the complaint:
Certified mail, restricted delivery
served on November 27, 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:
March 21, 2000 ; bydefendant March 21, 2000
by plaintiff
(b) (1) Date of execution of the affidavit required by §3301(d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4. Related claims pending: The parties incorporate but do not merge their
Property Settlement and Se aration Agreement dated March 21 2000.
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:
(b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: March 30, 2000
Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with
the Prothonotary: March 30, 2000
Attorney for Plainlifl/?rdf6ddF'
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DEBRA J. KECK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff' : CUMBERLAND COUNTY, PENNSYLVANIA
: NO. QQ - 7Ut 17 CIVIL TERM
vs.
CIVIL ACTION--LAW
SANDY A. KECK,
Defendant 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 in 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 ol'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 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
DIi11RA .I. KECK. IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, ITNNSYLVANIA
NO. 99- 7v/9 CIVIL'I'BRM
V5.
CIVIL ACTION--LAW
SANDY A. KECK,
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff' is DEBRA J. KECK, who currently resides at P.O. Box 61, Walnut
Bottom, Cumberland County, Pennsylvania.
2. Defendant is SANDY A. KECK, who currently resides at 405 High Mountain
Road, Shippensburg, Cumberland County, Pennsylvania.
3. Plaintiffand defendant have been bona fide residents in the Commonwealth for
at least six months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on June 12, 1977 at Carlisle,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and that plaintiff may
have the right to require the parties to participate in counseling.
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DEBRA J. KECK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. : 99-7019 CIVIL TERM
SANDY A. KECK,
Defendant : IN DIVORCE
AFFIDAVIT OF SERVICE.
AND NOW, this 3P day of Af'fz -e4 2000,
comes Dirk E. Berry, Esquire, and certifies that he mailed a true and correct copy of the
above-captioned matter to the defendant by certified mail, restricted delivery. Said return
receipt is attached hereto indicating service was made on November 27, 1999.
The Law Office of James K. Jones, Esquire
Dirk E. Berry?uire
Attorney for Plaintiff
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
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SANDY A. KECK,
Defendant
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NO. 99-7019 CIVIL TERM
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DEBRA J. KECK, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
NO. 99-7019 CIVIL TERM
v.
CIVIL ACTION--LAW
SANDY A. KECK,
Defendant : IN DIVORCE
19, 1999.
AFFIDAVIT OF CONSENT
A complaint in divorce under §3301 (c) of the Divorce Code was filed on November
2. The marriage of plaintiff and defendant is irretrievably broken and ninety 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 PENALTIES OF 18 PA.C.S. §4904 RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES.
DATE: - aZ ?'OD &L-Ij ? ace __l
DEBRA J. KECI(j
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DEBRA J. KECK, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
NO. 99-7019 CIVIL TERM
V.
CIVIL ACTION--LAW
SANDY A. KECK,
Defendant ; IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER §3301 (c) 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, lawyers
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. §4904 RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES.
DATE:_ -? / -bD plll- t-u 1 P-Lue ,
DEBRA J. KEC%t
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DEBRA J. KECK, : IN THE COURTOF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA
NO. 99-7019 CIVIL TERM
V.
CIVIL AC'I'ION--LAW
SANDY A. KECK,
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November
19, 1999.
2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have
elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree in 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. §4904 RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES.
DATE:_
SANDYA.d CK
C.
Cl.
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DEBRA J. KECK, : IN THE COURT OF COMMONPLEAS OF
Plaintiff : CUMBERLAND COUN'fY,PENNSYLVANIA
NO. 99-7019 CIVIL TERM
V.
CIVIL ACTION--LAW
SANDY A. KECK,
Defendant : IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO
REQUEST ENTRY OF A DIVORCE DECREE
UNDER §3301 (c) OF THE DIVORCE CODE
1. 1 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. §4904 RELATING TO UNSWORN
FALSIFICATION TO AUTHORITIES.
DATE: -31.211 a
SANDY A :CK
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DEBRA J. KECK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION -LAW
V.
NO. 99-7019 CIVIL TERM
SANDY A. KECK,
Defendant : IN DIVORCE
PRAECIPE
TO: Curtis R. Long, Prothonotary
Please enter the appearance of the undersigned and acknowledgment of receipt of
a certified copy of the Complaint in Custody on behalf of Defendant in the above-
captioned matter.
Date: October 3, 2000
Wayn F. Shade, Esquire
Attorney for Defendant
WAYNE F. SIIADI
Attorney at law
57 Wcst Pomfret 9rec
Carlisle. Pennsylvania
17013
52
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