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Home My WebLink About08-3252Lori M. Keller IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- 3a5a CIVIL TERM Tony L. Keller, Jr. 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 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, 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 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Lori M. Keller Plaintiff V. Tony L. Keller, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 08- CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is 6('-% M . Keller , who currently resides at N ..R. Cumberland County, Pennsylvania. \ 2. Defendant is Tong L. K?e, l Jr , who currently resides at 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. 5 Date Plaintiff, Pro Se I, ?ri I "i •e??rY , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: J-J9 Alaintiff, Pro Se Assisted by: Thomas I Williams, Esq. Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, PA 17013 (717) 243-1383 rl C"'r -- ca 3[y ? - _ ? j ?.? ???' ?,,, _ 1 ` ? '' ?', °-C Lori M. Keller IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08- 39.5a CIVIL TERM Tony L. Keller, Jr. Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Lori M. Keller, Plaintiff, to proceed in forma au eris. I, Thomas J. Williams, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. -- -I " kjj", Thomas J. W' isms, Esquire Attorney for Plaintiff Martson, Deardorff, Williams & Otto 10 E. High Street Carlisle, PA 17013 (717) 243-3341 c;- r C Lori M. Keller IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 08,32-Q Q CIVIL TERM Tony L. Keller, Jr. Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, 1jj'Ai21n& being duly sworn according to law, depose and say that on (Date of signing of the green card by spouse), I served a true and correct copy of the Divorce Complaint upon the Defendant, by Certified Mail, Restricted- Deliver, addressed as follows: The Certified Mail Return Receipt Mailing Card ("Green Card"), for the foregoing is attached hereto and made a part hereof. L , A V4 Signature Printed Name Sworn to and subscribed before me a Notary Public in and for Cumberland CouT Pennsylvania this day of?.&Ae- , 2008. , J110 A.? TARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Shelly Brooks, Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 5, 2009 Member, Pennsylvania Association of Notarlwr My commission expires: A ?Z &f f XggZ, 77 ¦ Complete Items 1, 2, and 3..Also complete 'f4 Signature Rem 4 If Restricted Delivery is desired. E3 Agent fa Print your name and address on the reverse x 0 Addressee so that we can return the card to you. B. J C. Date of Delivery ¦ Attach this card to the back of the mailplece, ' .P Jr. or on the front if space permits. D. Is deltv6v address different L WjWjA?, .'-7 Yes 1. Articiq to: II A. If YES, enter delivery ~ • v ?a ?n L,, r?Ll?JI. r` 9 Ch UA10o 3. Type ' C•rt %d Mall ? E>qt 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 G.O.D. 4. Restricted Delivery? p ft Fee) JeYes 2. ArtidfeNumber 7003 3110 0004 5772 5603 (Transfer fart m -in bW PS Form 3811. February 2W 8orrtaat o IAa11RTt Rsoaipt 1490115419-M-15401 M , (Domestic Mail Only: No In suranc e Coverage Provided) Lrl For delivery information visit o ur webs ite at www.usps.com G Hl iF1[? I Ln Postage $ $0.59 0013 Certified Fee $2.70 I . 0 , C3 0 Return Redept Fee (Endorsement R•QutZ $2.20 PastrneYk `? ,. Flare } C3 Rsslrkk?ed Delivery Fee ? (Endorsement Required) $4.30 f ra 'f m ' Total Postage & Fees $ $9.79 ; +?5l27%20f1$ M C3 Sam ° or PO Box No. JI, t Al) ` ?4 Lori M. Keller IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO.08-32S2- CIVIL TERM Tony L. Keller, Jr. Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on 01 1 1 23,7-002- 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 divorce. 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 unsworn falsification to authorities. Date: l O Signature: To y L. Keller, Jr., Defendant r srP M - ^ " C'a GTi Lori M. Keller Plaintiff v. Tony L. Keller, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.08-3LSZ. CIVIL TERM 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.,40twyer'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 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: i / Z' Signature: -?' To L. Keller, Jr., Defendant ' C > cn 7:1 Lori M. Keller Plaintiff V. Tony L. Keller, Jr. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.08-3o2SZ CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A c mplaint in divorce under §3301(c) of the Divorce Code was filed on o0Y 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 divorce. 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 unsworn falsification to authoritie Date: Signature: 4'40?j Lori M. Keller, Plaintiff p rya c.n Lori M. Keller IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. o&32 SZ CIVIL TERM Tony L. Keller, Jr. Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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,4awyer's fees or expenses if I do not claim them before a divorce is granted. \N . 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 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: ? - Signature: Lori M. Keller, Plaintiff jrn „ Y f U Created: 9/20/04 0:06PM Revised: 9/22/08 3:08PM Thomas J. Williams, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 17512 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff LORI M. KELLER, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA TONY L. KELLER, JR., Defendant NO. 08-3252 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Via certified mail, restricted delivbery on May 30, 2008, see Affidavit of Service, filed. 3. Date of execution of the Plaintiffs affidavit of consent required by Section 3301 (c) of the Divorce Code; September 11, 2008; by the Defendant; September 12, 2008. 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 19, 2008. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: September 17, 2008. MARTSON LAW OFFICES By `10-140--? 69 V-0 ?----? Thomas J. Williams, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff Date: September 22, 2008 ? ,.-- c/? ?? - ? - 't_ ? ???? ? ? ?_ . ?,, ? ? ? . ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LORI M. KELLER. Plaintiff No. 08-3252 VERSUS TONY L. KELLER, JR., Defendant DECREE IN DIVORCE • f AND NOW, 36 `?, IT IS ORDERED AND DECREED THAT LORI M. KEL ER , PLAINTIFF, AND TONY L. KELLER, 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; NONE. PROTHONOTARY moo. ?-o/