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Home My WebLink About03-6176 VALLERY C. MCKEEHAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW ROGER W. MCKEEHAN, Defendant : NO. 03 - ;'/7f.p : IN DIVORCE CIVIL NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, 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 TillS 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 32 SOUTH BEDFORD STREET CARLISLE, P A 17013 717-249-3166 VALLERY C. MCKEEHAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : CIVIL ACTION - LAW ; NO. 03 - ~ ('1" CIVIL : IN DIVORCE ROGER W. MCKEEHAN, Defendant COMPLAINT Plaintiff, Vallery C. McKeehan, by her attorneys, Broujos & Gilroy, P.c., sets forth the following: 1 Plaintiff, Vallery C. McKeehan, is an adult individual residing at 95 McAllister Church Road, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Roger W. McKeehan, is an adult individual residing at 95 McAllister Church Road, Carlisle, Cumberland County, Pennsylvania. 3 The parties were married on March 9, 2002, in Cumberland County, Pcnnsylvania. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge ofthe Plaintiff. 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. BROUJOS & GILROY, P.c. ByO)it) Hubert X. Gilroy, Attorney for Plai iff Broujos & Gilro , P.c. 4 North Hanover Street Carlisle, P A 17013 717-243-4574 I verify that the statements in the foregoing pleading 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. '-Ya.ih t. 7l1CJ!d,u-Y} V ALLFfiV C. McKEEHAN ~ ~ "- 0 ~ ~ 'l. ~' ... ,.".~ 0\ , ........ 10 <j ~ , ~ \ ~ ~ N . .' () ~ ." ....." 3301(c).not VALLERY C. MCKEEHAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : 03-6176 CIVIL TERM ROGER W. MCKEEHAN, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE, UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was fIled on November 24, 2003. 2. Defendant acknowledges receipt and accepts servicle of the Complaint on or about November 25, 2003. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. I understand that I will not be divorced until a Divorc::e 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~904 relating to unsworn falsification to authorities. Date: /2/- /1o-t5Y c r, '-1};JI 1J1l(~ ~\1cKeehan/Plaintiff --,,";T '." ._c... 1""-"> ., ~ __ 1 C'.. t',,) r',' 1. ,.,-, -~ 3301 (c).not VALLERY C. MCKEEHAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v 03-6176 CIVIL TERM ROGER W. MCKEEHAN, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330l(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on November 24, 2003. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about November 25, 2003. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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 Prothonotl!ry, . . .._ 7, I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. -,., (' Date: d ."",-0.) ~, ~_ i"f-~ Roger W. McKeehanlDefendant .\ .:;\ \'"\-\ \)'. VALLERY C. MCKEEHAN, Plaintiff, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 03-6176 CIVIL ROGER W. MCKEEHAN, Defendant, : IN DIVORCE AFFlflA VTT OF SRRVTCF, I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant, Roger W. McKeehan by certified mail on November 25, 2003. A copy of the Certified Mail - Return Receipt Requested, Restricted Delivery, is attached hereto and marked Exhibit A. /)_Jo-IJ..r DATE Hubert X. Gilro squire Attorney for P ntiff Broujos & roy, P.c. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 · CompJe1e items 1, 2, and 3. AlsO complete Rem 4 if Restricted Delivery Is desired. · . Print your "aIlle,afldaddresson the ~verse so thcrt We pan retumthecard to you. " · Attach lhis card to the back, oflhe _'pi~, or on the front If space P<ll'n)i1s. 1. ArticJo Add_ 10: Roger If. McKeehan 95 McAllister Church Road Carlisle, PA 17013 o Agent o Add...... C. Date of Dellvel) \ "~-s:' <0", 0.18 depv..y 8ddless diffomot from nom 11 0 Yes '/f\'$, llnIer delive,y address below: 0 No 3. ~ce Type , }:If. Cel1ltIed Mall P Oexp,... Ma/I 'j!( R~ Receipt for Men:handrse tJ 0.0:0. . IExtti Fee) ~ Yes 102595-02~1S40 r J UNITED SrA1ES POSTAL SERVICE , I . Sender. Please Print YOur name, address, and ZIP+4 in this box. 1/1111 Flrsl-G/ilss Milil ~e lIFees Paid U:;>PS, Pelll1R No. G-10 Hubert X. Gilroy, Esquire Broujos & Gilroy, P.c. 4 N.' Hanover Street Carlisle, PA 17013 Re: McKeehan EXHIBIT I ,4 .....' 0 n C_::l ,,:."'C} -r\ r:..J'"\ (-- c::: I-- I'> CJ -c1 - F .r:~ " ~::t 0 ~~:... U\ Ii\~\ First-Class Mail f'oStaglll!< Fees Paid U$PS, periJlil No. G-10 ZIP+4 in this box . llubertX.Gilroy, Esquire llroQjos & Gilroy, p.e. 4 N" Hatlover S1;reet Carlisle, PA 11013 Re: McKeehatl VALLERY C. MCKEEHAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 2003-6176 CIVIL ROGER W. MCKEEHAN, Defendant : CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section 03301(c) (x)330l(d)(l) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: November 11, 2003 by First Class Certified Mail, Return Receipt requested. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff: Month Day, 2005; by Defendant: Month day, 2005. (b) (1) Date of execution of the Plaintiff's affidavit required by Section 33010 of the Divorce Code: _2) Date of service of the Plaintiff's affidavit upon the Defendant: February 28, 2005. 4. Related claims pending: None. 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to me praecipe to transmit record, a copy of which is attached: July 20, 2005. (b) Date Plaintiff's Waiver of Notice was med with the Prothonotary: December 22, 2004. (b) Date Defendant's Waiver of Notice was med with t Prothonotary: March 11, 2005. H rt X. . roy, Attorney for PI . Broujos & Gilr ,PC 4 North Hano er Street Carlisle, PA 17013 717-243-4574 .-, '~?, .~,j\ f"," C-' - -- C' ,-r. - -- . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . .. . . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF VALLERY C. MCKEEHAN, Plaintiff No. VERSUS ROGER W. MCKEEHAN, Defendant DECREE IN DIVORCE ",,"::: T:::;<L~ ~ ~ ROGER W. MCKEEHAN AND ARE DIVORCED FROM THE BONDS OF MATRIMONY, PENNA, 2003-6176 r __~ 61,) ,.-'VV ,IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, :t;:+';+'+, Of . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BE:EN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None - "i /' ,/ / .. " '- ":".........-...;..J Tf:::6 ." ,.' ..:: ~ .~ '--i....~ ...: BY -,....... - '" .. -~ . ~. -. ~ ATTEST: ---/ --- -, -. . ~ '" , --..w ................ ,./~~. -./ . .' "- ./ '. ."". ~ 1'.;;,. ............... -;0' '. ...... "'.; " 'f \,;,.... ...-.. -"" CwJ.~ l -, . . :+;;f.:f.:f . <' .. 't' +.+.+. Of ;+.:f. +.;1;:+'" .. . . . . . . . . . . . . . . . . . . . J. . . . . . . . . .' ~y :z -r-.: qw, 505e L tJ.p<_jp ~~ ;t4;> .rv y5tL , .:. ",t , .. , ' . ~.. - B@/B9/2BB5 15:33 7172438227 BROUJOS & GILROY, PC PAGE B2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VG.\le<) t- V'''\C \<. t (\\0- r\ Plaintiff Vs FileNo. )(X)3 - oG II ~ IN DIVORCE ~cy-e.-r \)0. 'N\c...\(-e.€.,\/V~V\ . Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff I defendant in the above matter, [select one by m31'king "x"] pdor to the entry of a Final Decree in Divorce, or X after the entry of a Final Decree in Divorce dated 1u.\~ .~ d<>O;) hereby elects to resume the prior surname of Vo..\\t.c~ A......-ncc C' .\ oV.-<;e. , and gives this written notice avowing his I her intention pursuant to the p{Qvisio~ of S4 P.S. 704. t 7/J~ It. t Date: ;5/ / / /0<) V~1 a Cfwrvs::O ~7/a>>; . /Ir.~ , ! Signature (t,'7"C, 9 an..:;) of name being resumed COMMON COUNTY OF ) Onthe lA,it day of -'~M~ ,200~beforeme,theProthonotaryorthe notary public, personally ap the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he I she executed the foregoing for the pUl'pOse therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. . ~.. ',,)'.,... ,",\: ~ i{;r..' ,:':r ' '\ r::',l-'i' "" " '. ~.',,' ~;. f:} ~":i..:'~.',~' ',t "::..;..';":';:'.!::" 'N: ./':, .,-'~ lF~ " :,-''''f, .....;., -6~ Api!'~ Notary ~ublic NOTARIAl SEAL ~""gr:NOTARY. NOTARY PUBUC MY COMMIS~SU~'AN COURTHOUSE ~..,.'., UARY 2, 2fn; u ~ ~\\~ -- f :--! 6' ~ "-l \ ~ o ~ ~ v:s.. ~ ~ n.,cn ~ 7" ~ ,~: c:= .~. ~~::. :: ~m;n ~C' - ,.J--~ ~ ~~ : ~~ =2 " ""' o 15 -<