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HomeMy WebLinkAbout08-3107i A Thomas D. Gould, Esquire I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 KAREN J. KECKLER, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMERLAND COUNTY, PENNSYLVANIA V. THOMAS L. KZCKLER, DEFENDANT NO. 2008 -310? CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator's Office, Third floor, Cumberland County Courthouse, Hanover and High 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, GO TO-OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 KAREN J. KECKLER, PLAINTIFF V. THOMAS L. KECKLER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 t= 3 167 CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE 1. The Plaintiff is Karen J. Keckler who currently resides at 600 Bridge Street, New Cumberland, Cumberland County, Pennsylvania 17070. 2. The Defendant is Thomas L. Keckler who currently resides at 708 Hamilton Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Defendant have been bonafide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 5, '1972 in Allegheny County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. • 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. Thomas D. Gould Attorney for Plaintiff I.D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: AIAV? Ka en i6lecklc\T NOTICE CAF AVAILABILITY 9F COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(c) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. w v ?? ? m -rt -arn KAREN J. KECKLER, Plaintiff V. THOMAS L. KECKLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-3107 IN DIVORCE PETITION FOR MARRIAGE COUNSELING PURSUANT TO 23 PACSA SECTION 3302 SAMIS, FLOWER & LINDSAY ATIMMAX, 26 West High Street Carlisle, PA 1. Petitioner is Defendant, Thomas L. Keckler, who currently resides at 708 Hamilton Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Respondent is the Plaintiff, Karen J. Keckler, who currently resides at 600 Bridge Street, Cumberland County, Pennsylvania 17070. 3. Respondent filed a Complaint in Divorce on May 16, 2008 to the within matter. 4. Petitioner denies that the marriage is irretrievably broken. 5. Petitioner has been advised of the availability of counseling and that Petitioner may have the right to request that the Court require that the parties participate in counseling. 6. Petitioner requests the Court to require the parties to participate in counseling pursuant to 23 PACSA Section 3302. 7. A copy of this Petition has been forwarded to Respondent's attorney, Thomas D. Gould, Esquire. 8. There has been no prior judge assigned to this action. Respectfully Submitted, SAID , FL INDSAY Marylou a as, Esquire Attorne .84919 26 West High Street Carlisle, PA 17013 / n (717) 243-6222 Dated: I? G Counsel for Defendant VERIFICATION I verify that the statements made in the foregoing Petition for Marriage Counseling are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsifications to authorities. Q Date: Dg homas L. Keckler SAWIS, FLOWER & LINDSAY AMP I W 26 West High Street Carlisle, PA CERTIFICATE OF SERVICE On the I 7-M day of u? , 2008, I, Judith L. Derr, of the law firm of SAIDIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, by regular U.S. Mail as follows: Thomas D. Gould, Esquire 2 E. Main Street Shiremanstown, PA 17011 SAIDIS, FLOWER & LINDSAY )44 -- )k - Judit . Derr 26 West High Street Carlisle, PA 17013 717-243-6222 SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA ?? 5_Y ,x? ?, ?, `? r t.U ; C _ 1 4 ... _ l ...,-,. i' 4 9 r ?. '" ? " ? Y ''? ..... S. .?...? KAREN J. KECKLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 2008-3107 THOMAS L. KECKLER, Defendant IN DIVORCE DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT IN DIVORCE SAMIS FLOWER '& 104DS" 26 West High Street Carlisle, PA 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. The Defendant denies that the marriage is irretrievably broken. Proof thereof is demanded at trial. 7. Admitted. 8. The Defendant does not have sufficient information available to form a belief as to the truth of this statement. 9. Admitted. WHEREFORE, the Defendant requests this Honorable Court to dismiss the Complaint in Divorce. Respectfully submitted, SAI91S,.FLO,WEfZ4 LINDSAY Dated:// /ce Attor y I 84919 26 Wes igh Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ?S r` Y VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. Thomas L. Keckler Date: O rl g1 bg RJOWWER ? LINDSAY 26 West High Street Carlisle, PA CERTIFICATE OF SERVICE On the I q"' ' day of ?` L'? , 2008, I, Judith L. Derr, of the law firm of SAIDIS, U FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, by regular U.S. Mail as follows: Thomas D. Gould, Esquire 2 E. Main Street Shiremanstown, PA 17011 SAIDIS, FLOWER & LINDSAY LW"? LL?2)- Judit . Derr 26 Mist High Str t Carlisle, PA 17013 717-243-6222 FLOWER ? LINDSAY 26 West High Street Carlisle, PA jn KAREN J. KECKLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 08-3107 CIVIL THOMAS L. KECKLER, Defender IN DIVORCE IN RE: PETITION FOR MARRIAGE COUNSELING ORDER AND NOW, this Z:7- day of August, 2008, a rule is issued on the plaintiff to show cause why the relief requested in the within motion ought not to be granted. Said rule returnable twenty (20) days after service. BY THE COURT, ?omas D. Gould, Esquire For the Plaintiff , ,01 arylou Matas, Esquire For the Defendant :rlm a: c C\j 17 c` cl-i LIJ lJ - CV 0 If EL - O'r i > '/Tip {+' It t a r' KAREN J. KECKLER, JN THE COURT OF COMWMETMS 09 Z' 4 3 Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA CUMBERLAND COUNTY :CIVIL ACTION - LAW PENNSYLVANIA V. :IN DIVORCE THOMAS L. KECKLER, Defendant :NO. 2008 - 3107 STATEMENT OF INTENTION TO PROCEED To the Prothonotary: Please be informed that the Plaintiff, Karen J. Keckler, intends to proceed with the divorce action and respectfully asks that this matter not be terminated. DATED: J4??! J??I ilz4abhh 1 Of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, Pennsylvania 17108 (717) 233-7691 co C=) a - T C- f .."' 4....e D NJ ? .. t .? A .e W CERTIFICATE OF SERVICE I, Elizabeth S. Beckley, Esquire, hereby certify that a true and correct copy of the foregoing document was this day served upon the person and in the manner indicated below. SERVICE BY FIRST CLASS MAIL: Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043-0168 DATED: iza eth . ec r Karen J Keckler, In the Court of Common Pleas Plaintiff Cumberland County, Pennsylvania c-! a? No. 2008 -3107 Civil term 4 'r ' Thomas L Keekler In Divorce 1' = 3 , Defendant zr AFFIDAVIT OF CONSENT -- 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 16 2008, and service was obtained upon the Defendant on May 20 2008 by Defendant personally accepting service thereof. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date:_ C2 V-Z- are J Kec Karen J Keckler, In the Court of Common Pleas Plaintiff Cumberland County, Pennsylvania No. 2008 -3107 Civil term r V - ` . Thomas L Keckler, In Divorce -- ' Defendant : " c- - WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. Date: 9 K en Keckler Karen J Keckler, Plaintiff V. Thomas L Keckler, Defendant 2 2 ?E?1F?S`f LVAt?I, m a In the Court of Common Pleas Cumberland County, Pennsylvania No. 2008 -3107 Civil term In Divorce ACCEPTANCE OF SERVICE I, Samuel L Andes, Esquire, counsel for Defendant, Thomas L Keckler, hereby acknowledge that on May 20, 2008, Defendant was served with a certified copy of the May 16, 2008 divorce complaint filed to the above term and docket and, service thereof was effectuated in accordance with PA RCP 1920.4 et seq. Date:( p_( Z el L Andes, squire Counsel for Defendant, Thomas L Keckler 525 North Twelfth Street P.O. Box 168 Lemoyne, Pennsylvania 17043 (717) 761 5361 y KAREN J. KECKLER, Plaintiff VS. THOMAS L. KECKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008-3107 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 16 May 2008 and served upon the Defendant on 20 May 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. Section 4904 relating to unworn falsification to authorities. 0, /// y- Dated: Z- / THOMAS L. KECKER Karen J Keckler Plaintiff IN "THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. Thomas L Keckler CIVIL DIVISION Defendant ; NO 2008-3107 CIVIL TERM C-) PRAECIPE TO TRANSMIT RECORD -03 To the Prothonotary: cn -< r:z or& Transmit the record, together with the following information, to the court for entry of a di decree: 3> C I. Ground for divorce: Irretrievable breakdown under § (3301(c)) and (Strike out inapplicable section.) 2. Date and manner of service of the complaint: Defendant was served with certified copy of the May 16, 2008, divorce complaint on May 20, 2008. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce code: by plaintiff May 29 2012 ; by defendant June 14 2012 (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiffs § 3301(d) affidavit upon the respondent opposing party: 4. Related claims pending: No related claims pending 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 plaintiffs Waiver of Notice was filed with the Prothonotary: June 1 2012 Date defendant's Waiver of Notice was filed with the Prothonotary: June 21 2012 Camp Hill PA 17011 717 737 6400 p; 717 737 5355 f Attorney f • Plaintiff/" efeftdaw Jame??A Miller, Esq ER LIPSITT LLC 4 S 17th St N C- c r tV N X- C-n ?f r= bra CD --i C.? p? C:: ?s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANI Karen J Keckler V. Thomas L Keckler No. 2008-3107 DIVORCE DECREE ? 14 ,0(7- AND NOW, it is ordered and decreed that Karen J Keckler plaintiff, and Thomas L Keckler , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None the Court, Attest: tFba*S A. IPc OG-J Prothonotary ropy 1ivtie of -1-o p/?CIL'