Loading...
HomeMy WebLinkAbout09-2993t • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Elaine J. Keck Plaintiff vs. Joel M. Keck Defendant : Civil Action -Law No. F.R. 2009- 619q3 In Divorce a.v.m. Civa Terri 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 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 on the first floor of the Cumberland County Court House, Hanover and High Streets, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVI- SION 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 CAN- NOT AFFORD ONE 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 INFOR- MATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PENNSYLVANIA BAR ASSOCIATION LAWYER REFERRAL SERVICE P.O. Box 186 Harrisburg, Pennsylvania 17108 TELEPHONE: [800] 692-7375 [PA only] or [717] 238-6715 AMERICAN WITH DISABILITIES ACT OF 1990 The Court of common Pleas Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. for information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrange- ments must be made at least seventy-two [72] hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. { IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Elaine J. Keck Civil Action -Law Plaintiff vs. No. F.R. 2009- 94 3 C Q Joel M. Keck Defendant In Divorce a.v.m. COMPLAINT UNDER §3301[C] OF THE DIVORCE CODE 1. Plaintiff is Elaine J. Keck who currently resides at 262 Ridge Road, Cumberland County, Shippensburg Pennsylvania, 17257 since November of 1997. 2. Defendant is Joel M. Keck who currently resides at 262 Ridge Road, Cumber- land County, Shippensburg Pennsylvania, 17257 since November of 1997. 3. Plaintiff and 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 July 25, 1993 at Hopewell Town- ship, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The plaintiff has been advised of the availability of counseling and the plaintiff has the right to request that the court require the parties hereto to participate in counsel- ing. 8. Plaintiff requests the court to enter a decree of divorce. 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. May 11, 2009 May 11, 2009 Attorney for Plaintiff - 16767 Path Valley Road P.O. Box 51 Spring Run, PA 17262-0051 I . D. # 36406 [717] 349-7657 J - 4 ?flQ4 MAI Y 12 PH 3: 1 7 CVt?v ., ?.wE?ui Y J T 338. 5o PO way Cie-V 14 A 19 RT* 'R.257,033 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Elaine J. Keck Civil Action -Law Plaintiff vs. No. F.R. 2009-,29q3 C! o L J E ?w+ Joel M. Keck Defendant In Divorce a.v.m. AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Wayne Shade, Esquire, Attorney of Record for Joel M. Keck, the Defendant in the above-captioned action, did receive a true and correct copy of the Complaint Under §3301© of the Divorce code, docketed to the above-captioned action, on May /!?_, 2009, at 53 West Pomfort Street, Carlisle, PA 17013. VERIFICATION 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: 5 2. 0 q X4114 /Q?"_ Wayne ade, Esquire Attorney for Defendant 2 609 K,fiY 22 Pf'I v: 3 E IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Elaine J. Keck Civil Action -Law Plaintiff vs. : No. F.R. 2009- ?03 Joel M. Keck Defendant In Divorce a.v.m. AFFIDAVIT OF ACCEPTANCE OF SERVICE I, Wayne Shade, Esquire, Attorney of Record for Joel M. Keck, the Defendant in the above-captioned action, did receive a true and correct copy of the Complaint Under §3301© of the Divorce code, docketed to the above-captioned action, on May /:, 2009, at 53 West Pomfort Street, Carlisle, PA 17013. VERIFICATION 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: 42 t °PC d T Lt! Wayne Wade, Esquire Attorney for Defendant 2 0 0 9 flAY 7 PIli' * : 0 S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Elaine J. Keck :Civil Action -Law Plaintiff vs. No.09-2993 Joel M. Keck Defendant In Divorce a.v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 12, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. VERIFICATION 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: q g ~ u _l Elaine J. K k ~{t ~~~^~1__~~''~ r' +1 i-Il~f..tj~f~~f lVl~. 20Q9 OCT -2 pM 2~ ~a 4 PL.~~4iJ\i f~Yl'U ~:i~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA Elaine J. Keck Plaintiff vs. Joel M. Keck Defendant Civil Action -Law X993 No. ^~.~ In Divorce a.v.m. 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, 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. VERIFICATION 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: 3~ Elaine J. 2009 OCT -2 P~ 2~ ~ ~- ~~P;~+~S~rLt~~P~t~