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Home My WebLink About01-1194NIKKI L. McKEEVER VS. SHAWN M. McKEEVER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. -/lCt/tr CIVIL ACTION -- LAW DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED 1N 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 AT THE CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA 17013. 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 NIKKI L. McKEEVER VS. SHAWN M. McKEEVER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW DIVORCE COMPLAINT UNDER §3301(c) or §3301(d) OF THE DIVORCE CODE 1. The plaintiff is NIKKI L. McKEEVER, who currently resides at 603 Fifth Street, New Cumberland, Cumberland County, PA 17070, since February 23, 2001. 2. The defendant is SHAWN M. McKEEVER, residing at 5435 Spring Road, Shermansdale, Perry County, Pennsylvania since January 30, 2001. 3. There is one minor child of the parties, Brenden M. McKeever, dob 8/29/98. 4. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing o£this Complaint. 5. The Plaintiff and Defendant were married November 7, 1998 at Meehanicsburg, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or annulment between the parties. 7. Neither party is presently a member of the Armed Forces on active duty. 8. The parties have entered into a written agreement as to alimony, counsel tees, costs, and property division. 9. Plaintiffhas been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. The marriage is irretrievably broken. 11. Plaintiffavers that the ground on which the action is based is that the man/age is irretrievably broken. 12. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the Court enter an Order dissolving the marriage between the Plaintiff and Defendant. Dated: Respectfully submitted, Timel~¢:. C~olg~,~ire WILEY, LENOX, COLGAN & MARZZACCO, P.C. 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 I.D. #77944 VERIFICATION I, NIKKI L. McKEEVER, 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 herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to tmswom falsification to authorities. NIKKI L. McKEEVER Plaintiff C:~ERVER~IISERVERICLIENT~ICOLG~IN~MCKEEVERICOMPL41A~WPD NIKKIL. McKEEVER VS. SHAWN M. McKEEVER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1194 CIVIL ACTION - LAW DIVORCE SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1(a)(3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE. DOCKET NO. 01-1194 PLAINTIFF SS NO. NAME 182-52-0154 NIKKI L. McKEEVER DEFENDANT SS NO. 210-56-0154 NAME SHAWN M. McKEEVER NIKKI L. McKEEVER VS. SHAWN M. McKEEVER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1194 CIVIL ACTION -- LAW DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on March 1, 2001. 2. The marriage of Plaintiffand Defendant is h'retrievably broken and ninety (90) 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 tree and correct. I understand that false statemems made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Date NIKKI L. McKEEVER Plaintiff N1KKI L. McKEEVER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 01-1194 SHAWN M. McKEEVER Defendant CIVIL ACTION -- LAW DIVORCE WALVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree ofdivome 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 divome is granted. 3. I understand that 1 will not be divomed 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. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. {}4904 relating to unswom falsification to authorities. Date NIKK1 L. McKEEVER Plaintiff NIKKI L. McKEEVER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 01-1194 SHAWN M. MeKEEVER Defendant CIVIL ACTION -- LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDF~R 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. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. te Defendant NIKKI L. MeKEEVER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. No. 01-1194 SHAWN M. McKEEVER Defendant CIVIL ACTION -- LAW DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under §3301(c) of the Divorce Code was filed on March 1, 2001. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) 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. 1 verify that the statements made in this affidavit are tree and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities, Date SHAWN M. McKEEVER Defendant NIKKIL. McKEEVER VS. SHAWN M. McKEEVER TO THE PROTHONOTARY: decree: Date: Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1194 Defendant CIVIL ACTION -- LAW DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the Court for entry of a divome 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c). 2. Date and manner of service of the Complaint: First Class Mail. Certified Mail. Restricted Delivery. An Affidavit of Service evidencing same has been filed withthe court. 3. Complete either Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divome Code: By Plaintiff: November 15. 2001; By Defendant: November 10. 2001. (b) (1) Date of execution of the Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 4. Related claims pending: Them am 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 in Section 3301(c) Divorce was filed with the Prothonotary: Filed October 17. 2001. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Filed December 10. 2001. Timothy J. Co~ Attorney for Plaintiff NIKKI L. McKEEVER VS. SHAWN M. McKEEVER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1194 Defendant CIVIL ACTION -- LAW DIVORCE AFFIDAVIT OF SERVICE I, Michele A. Reneker, being duly sworn, deposes and says that she is an adult and that she served the Complaint on the Defendant, at the Defendant's last known address as follows: Shawn M. McKeever, P.O. Box 191, Shermansdale, Pennsylvania, 17090, by certified mail, restricted delivery, on the 15th day of March, 2001. A copy of the PS form 3811 is attached hereto, marked Exhibit "A' and made a part bereof by reference thereto. Date: December 19, 2001 By: THE WlLEY GROUP Michele A. Reneker, Secretary to Timothy J. Colgan, Esquire COMMONWEALTH OF PENNSYLVANIA: . : SS COUNTY OF : On this, the I~ day of December 2001, before me, a notary public, personally appeared Miehele A. Reneker, known to me or satisfactorily proven to be the whose name is subscribed to the within Affidavit and acknowledged that she executed the same for the purposes therein contained. WITNESS, my hand and notarial seal the day and year aforesaid. item 4 if R~'tflcted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits· 1. Article Addressed to: A. F~m3e~d by ~Weeee Pn~ Ctea~.) Date of Delivery x If YES, ent..elive~ add.~ be~l ?~No ~"ifi~ Mail ~ Exp~ Mail 2. Article Number (Copy from service label) PS Form 3~1 1, July 1999 Dom~tic Return Re(~pt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE:. OF ~ NIKKI L. McWEEVER Plaintiff PENNA. N O. 01-1194 VERSUS SHAWN M. McKEEVER Defendant DECREE IN DIVORCE AND NOW, DECREED THAT AND NIKKI L. McKEEVER SHAWN M. McKEEVER , IT IS ORDERED AND , PLAINTIFF, , 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; No related claims pending. PROTHONOTARY